Justia Ohio Supreme Court Opinion Summaries

Youngstown Belt Railway Company entered into a purchase agreement with Total Waste Logistics of Girard for the purchase of Mosier Yard, which the railway owned. The sale was never consummated, and later the city of Girard commenced an appropriation action to appropriate a portion of Mosier Yard. The trial court held that the city's appropriation proceedings were preempted by the Interstate Commerce Commission Termination Act (ICCTA). On remand, the trial court held that it would be inappropriate to consider the railway's potential sale to Total Waste in the preemption analysis but determined that the railway's use of a portion of the appropriated land for storage caused the city's action to be preempted by the ICCTA. The appellate court affirmed, although on different grounds. The Supreme Court reversed, holding that the city's proposed eminent-domain action against the undeveloped portion of the railway's property, which did not contain any tracks or rights-of-way and did not have any concrete projected use that would constitute rail transportation by a rail carrier, was not preempted under the ICCTA. View "Girard v. Youngstown Belt Ry. Co." on Justia Law

The question before the Supreme Court in this case was whether the city of Cuyahoga Falls was immune from liability, pursuant to Ohio Rev. Code 2744, in an action brought by a minor and his parents after the minor was injured at an indoor swimming pool maintained by the city. The trial court granted summary judgment in favor of the city on the ground that indoor swimming pools do not fall under section 2744.02(B)(4), which sets forth an exception to immunity for injury caused by negligence of a political subdivision's employee within or on the grounds of a building used in connection with a governmental function. The court of appeals reversed, concluding that the pool was in a building used in connection with the performance of a governmental function, and therefore, the exception to political-subdivision tort immunity applied. The Supreme Court affirmed, holding that the city was not immune from liability because the exception to immunity contained in Ohio Rev. Code 2744.02(B)(4) was applicable. View "M.H. v. City of Cuyahoga Falls" on Justia Law

In this case, the Supreme Court was asked to resolve a certified conflict between the fifth and second district courts of appeals on whether res judicata bars a criminal defendant from arguing that his plea is void due to an earlier postrelease-control sentencing error when the defendant has entered a plea of guilty to escape. The Supreme Court held that if a trial court improperly sentences a defendant to a term of postrelease control and the defendant subsequently pleads guilty to violating the terms of that postrelease control, the defendant is not barred by principles of res judicata from collaterally attacking his conviction as void. In so holding, the Court reversed the judgment of the fifth district court of appeals, which affirmed the trial court's denial of Defendant's motion to withdraw his guilty plea to escape on the theory that he had never been legally placed on postrelease control. View "State v. Billiter" on Justia Law

Appellant was charged with one count of domestic violence. The domestic-violence charge was enhanced to a third-degree felony under the statute applicable to third-time offenders. A jury found Appellant guilty. The court of appeals affirmed Appellant's domestic-violence conviction but as a fourth-degree rather than a third-degree felony because the state had not presented evidence of at least two prior domestic-violence convictions. The Supreme Court affirmed, holding (1) while Ohio Rev. Code 2945.75(B)(1) permits the state to prove a prior conviction by submitting a judgment entry of the conviction, the statute does not restrict the manner of proof to that method alone; (2) when the state chooses to prove a prior conviction by using a judgment entry, that entry must comply with Ohio R. Crim. P. 32(C); (3) the appellate court in this case was correct in holding that the state proved only one, not two, prior convictions, and therefore the offense may be elevated only to a fourth-degree felony; but (4) the court of appeals was incorrect in holding that compliance with Rule 32(C) was not a prerequisite to proving a prior offense for purposes of increasing a subsequent charge. View "State v. Gwen" on Justia Law

Appellant was found guilty of aggravated murder and tampering with the evidence. The trial court, however, granted Appellant's motion for judgment of acquittal on the aggravated-burglary count. The Supreme Court accepted Appellant's appeal to review two questions of law: (1) does a person have standing to object under the fourth Amendment to the retention of a DNA profile by the state and its use in a subsequent criminal investigation when the profile was lawfully created during a previous criminal investigation, but the person was acquitted of the crime; and (2) does the state have the authority to retain a DNA profile that was created during a criminal investigation and use that profile in a subsequent investigation, when the person was acquitted of any crime following the first investigation? The Supreme Court affirmed, holding (1) a person does not have standing to object to the retention of his or her DNA profile or the profile's use in a subsequent criminal investigation; and (2) the state is authorized to retain the DNA profile and to use it in a subsequent investigation even though the profile was obtained from a sample taken during the investigation of the crime of which the person was acquitted. View "State v. Emerson" on Justia Law

Federal Home Loan Mortgage Corporation commenced this foreclosure action before it obtained an assignment of the promissory note and mortgage securing the Plaintiffs' loan. Plaintiffs maintained that Federal Home Loan lacked standing to sue. The trial court granted summary judgment in favor of Federal Home Loan and entered a decree of foreclosure. The appellate court affirmed, holding that Federal Home Loan had remedied its lack of standing when it obtained an assignment from the real party in interest. The Supreme Court reversed and dismissed the cause, holding (1) standing is required to invoke the jurisdiction of the common pleas court, and therefore it is determined as of the filing of the complaint; and (2) thus, receiving an assignment of a promissory note and mortgage from the real party in interest subsequent to the filing of an action but prior to the entry of judgment does not cure a lack of standing to file a foreclosure action. View "Fed. Home Loan Mortgage Corp. v. Schwartzwald" on Justia Law

Pursuant to a plea agreement, the trial court found juvenile appellant J.V. delinquent and guilty of felonious assault, aggravated robbery, and the attendant firearm and serious-youthful-offender specifications. The court imposed a blended sentence of at least two years of incarceration at the Ohio Department of Youth Services and a stayed adult sentence of three years. Near the end of his sentence, J.V. was involved in a fight that led the trial court to invoke the stayed adult sentence. The court of appeals affirmed the invocation of the stayed adult sentence. The Supreme Court affirmed in part and reversed in part, holding (1) the invocation of the adult prison sentence was constitutional; but (2) a juvenile court does not have the authority to impose criminal punishment, including post-release control, after the delinquent child turns twenty-one, and because the juvenile court imposed the adult sentence and added postrelease control after J.V. turned twenty-one, the court acted outside of its jurisdiction. View "In re J.V." on Justia Law

At issue in this case was whether an indigent parent whose sentence for civil contempt at a previous hearing for failure to pay child support was suspended on condition that he comply with his child-support obligations for a year, has a right to appointed counsel at a subsequent hearing on a motion to impose the suspended sentence due to noncompliance with the conditions. The court of appeals (1) concluded that the Sixth Amendment right to counsel did not apply at the hearing, as it was civil in nature, and (2) declined to create a categorical rule that indigent parties previously represented by counsel at a contempt hearing have a due process right to appointed counsel at later purge hearings. The Supreme Court affirmed, holding (1) because a purge hearing does not amount to a new contempt proceeding, a hearing to determine whether a contemnor has purged himself of civil contempt is a civil proceeding; and (2) the Due Process Clauses of the state and federal Constitutions do not guarantee an indigent parent the right to appointed counsel at a civil-contempt purge hearing. View "Liming v. Damos" on Justia Law

Defendant shot Ulysses Altizer. At issue on appeal was Ohio Rev. Code 2941.146, which states that if a defendant fires shots "from a motor vehicle," he is subject to a mandatory, five-year prison term. During trial, the prosecution stated to the jury that Defendant did not have to be in the vehicle for the specification to apply. The jury convicted Defendant on two counts of felonious assault with two firearm specifications each, including the specification set forth in section 2941.146. The appellate court affirmed, holding (1) the statute was not unconstitutionally vague as applied to Defendant; and (2) section 2941.146 covered Defendant's conduct since the statute did not limit its application to persons engaged in proscribed activity inside a motor vehicle. The Supreme Court reversed and remanded, holding (1) section 2941.146 is not applicable when a defendant fires a weapon while standing with both feet planted on the ground with no substantial physical connection with a motor vehicle; and (2) therefore, the statute did not apply to Defendant, who discharged his weapon while standing outside his vehicle. View "State v. Swidas" on Justia Law

This was an appeal from a judgment of the court of appeals affirming a trial court's judgment granting a motion to suppress. At issue was whether the trial court abused its discretion in granting the motion to suppress after it determined that an officer knowingly and intentionally made false statements in his search-warrant affidavit. The Supreme Court reversed the judgment of the court of appeals, which upheld the trial court's ruling, holding (1) the officer's statements in his testimony did not amount to his knowingly and intentionally including false information in his search-warrant affidavit; and (2) therefore, the trial court erred in its judgment. Remanded for a new suppression hearing. View "State v. Dibble" on Justia Law