Justia Ohio Supreme Court Opinion Summaries

At issue in this case was whether, in general, cell-phone records produced by a cell-phone company constitute testimonial evidence that implicates a defendant's right to cross-examine a witness under the Confrontation Clause of the Sixth Amendment. Defendant here was convicted of murder, kidnapping, aggravated robbery, and aggravated burglary. Defendant appealed, arguing that the trial court had erred by allowing cell phone records to be admitted into evidence without being properly authenticated in violation of the Confrontation Clause. The appellate court determined that the admission of the cell-phone records did not contribute to Defendant's conviction and affirmed the judgment of the trial court. The Supreme Court affirmed, holding (1) because cell-phone records are generally business records that are not prepared for litigation and are thus not testimonial, the Confrontation Clause does not affect their admissibility; (2) however, the hearsay rule barred the records' admission in this case because they were not properly authenticated; but (3) the admission of the cell-phone records did not contribute to Defendant's conviction, and their admission was harmless beyond a reasonable doubt. View "State v. Hood" on Justia Law

In this certified conflict, the Supreme Court considered whether a trial court's failure to impose the statutorily mandated fine required by Ohio Rev. Code 2925.11(E)(1)(a) and 2929.18(B)(1) when no affidavit of indigency has been filed with the court prior to the trial court's journal entry of sentencing renders void the part of the sentence waiving the fine. The Supreme Court affirmed the judgment of the court of appeals in resolving the certified conflict, holding that a trial court's failure to impose the required fine under these circumstances renders void the part of the sentence waiving the fine, and that resentencing of the offender is limited to the imposition of the mandatory fine. View "State v. Moore" on Justia Law

This was an original action challenging the decennial apportionment of districts in the General Assembly. At issue was whether the 2011 apportionment plan adopted by the apportionment board (Respondents) complied with Ohio Const. art. XI, 7 and 11. The Supreme Court denied Relators' request for declaratory and injunctive relief, holding that Relators failed to adduce sufficient, credible proof to rebut the presumed constitutionality accorded the 2011 apportionment plan by establishing that the plan was unconstitutional beyond a reasonable doubt, and therefore, Relators were not entitled to a declaration that the 2011 apportionment plan was unconstitutional or a prohibitory injunction to prevent elections from being conducted in accordance with that plan. View "Wilson v. Kasich" on Justia Law

In this appeal, the Supreme Court was asked to determined whether Ohio Const. art. XII, 5a permits the use of motor vehicle and gas tax (MVGT) funds to pay those costs of a county's joint self-insurance pool attributable to covering the risk of liability and loss resulting from the operations of a county engineer's highway department. The Supreme Court concluded that Ohio Const. art. XII, 5a authorizes the use of MVGT funds to pay a county's cost of participating in a joint self-insurance pool attributable to covering the risk of liability and loss resulting from the operations of a county engineer's highway department. In so holding, the Court reversed the judgment of the court of appeals and remanded. View "Stockberger v. Henry" on Justia Law

Appellant, the former mayor of the city of Vermilion, appealed from a judgment denying her request for a writ of mandamus to compel Appellee, the city, to provide copies of certain itemized billing statements for attorney services rendered to the city. Because she thought the annual legal fees expended by the new administration would far exceed the fees incurred during her administration, Appellant made the records requests to permit public scrutiny of the city's expenditure of funds for legal services. The Supreme Court (1) reversed the portion of the court of appeals granting summary judgment in favor of the city and denying Appellant's claim for a writ of mandamus, as the city did not establish that the entirety of the requested statements were exempt from disclosure under the Public Records Act; and (2) affirmed the portion of the judgment denying Appellant's request for an award of statutory damages and attorney fees. Remanded. View "State ex rel. Anderson v. City of Vermilion" on Justia Law

In this case, the Supreme Court considered whether Appellant, Ohio Department of Jobs and Family Services (ODJFS), properly denied applications for federal wage subsidies filed by Appellees, three former employees of American Standard who later were reemployed at a lower wage before they reached the age of fifty. The Ohio Unemployment Compensation Review Commission denied Appellees' eligibility for the subsidies. The court of common pleas reversed. The Supreme Court reversed and remanded, holding that because ODJFS offered a reasonable interpretation of ambiguous language in the federal statute that established the wage subsidies, ODJFS did not improperly deny the applications. View "Lang v. Dir., Ohio Dep't of Job & Family Servs." on Justia Law

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