Justia Ohio Supreme Court Opinion Summaries

A jury convicted Wayne Powell of the aggravated murder of four victims and of aggravated arson. The jury recommended the sentence of death for the aggravated murder of the victims. The trial court accepted those recommendations and sentenced Powell accordingly. The Supreme Court affirmed Powell's convictions and sentences of death, finding no reversible error regarding (1) any pretrial and trial issues; (2) any penalty-phase issues; or (3) counsel's effectiveness during both phases of the trial. In addition, the court held that because Powell received a fair trial, the doctrine of cumulative error was not applicable to the present case, and Powell's death sentence was appropriate and proportionate. View "State v. Powell" on Justia Law

In this action the Cincinnati City School District Board of Education asked the Supreme Court to rule on the validity of a deed restriction it placed on school property that it offered for sale at a public auction. At issue was whether the deed restriction contravened public policy by preventing an unused school building from being used by a public charter school. The trial court concluded that the deed restriction was void as against public policy, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) because this case involved a contract between a private party and a political subdivision, there was a compelling reason to apply the principle of the public policy exception to parties' rights to make contracts; and (2) therefore, the inclusion of a deed restriction preventing the use of property for school purposes in the contract for sale of an unused school building was unenforceable as against public policy. View "Cincinnati City Sch. Dist. Bd. of Educ. v. Conners" on Justia Law

Defendant Carl Morris was convicted by a jury of two counts of rape involving a minor. Defendant appealed, contending that the trial court abused its discretion when it admitted evidence of other acts to prove the character of a person in order to show that the person acted in conformity therewith, in violation of Ohio R. Evid. 404(B). A divided appellate court vacated the conviction, concluding that the trial court improperly admitted other-acts testimony, that the court's error was not harmless, and that the error materially prejudiced Defendant. The Supreme Court reversed, holding (1) an appellate court is to apply an abuse-of-discretion standard of review when considering an assignment of error that claims the trial court improperly admitted evidence of other acts to prove the character of a person in order to show action in conformity therewith, in violation of Rule 404(B); and (2) the appellate court erred when it applied a de novo standard of review to this matter. Remanded. View "State v. Morris" on Justia Law

The Ohio Department of Health (ODH) issued several notices of violations of the Smoke Free Act to Appellants, a privately owned bar and its CEO. ODH subsequently filed a complaint seeking injunctive relief ordering Appellants to comply with the Smoke Free Act. Appellants filed a counterclaim for declaratory and injunctive relief against ODH and a cross-claim against the attorney general, alleging that the Smoke Free Act operated in violation of Appellants' constitutional rights, that the Act was invalid as applied to them, and that ODH engaged in rulemaking that exceeded its authority. The trial court held that ODH had exceeded its authority in implementing a policy of strict liability for violations of the Act by issuing fines regardless of whether Appellants were at fault and denied ODH's request for a permanent injunction. The court of appeals reversed and granted a permanent injunction to ODH. The Supreme Court affirmed, holding (1) because Appellants failed to exhaust their administrative remedies and could not use declaratory judgment to vacate final orders, the previous violations of the Act were res judicata; and (2) the Act was a valid exercise of the state's police power and did not amount to a regulatory taking. View "Wymsylo v. Bartec, Inc." on Justia Law

A jury found Defendant Donald Eafford guilty of permitting drug abuse and possession of cocaine. The court of appeals vacated Eafford's felony sentence for possession of cocaine and remanded for resentencing, holding that Eafford was convicted only of misdemeanor possession of drugs because the jury-verdict form did not state the degree of the offense or specify that Eafford had possessed cocaine. The Supreme Court reversed the court of appeals and reinstated the sentence, holding that the trial court did not plainly err in imposing sentence, as (1) the indictment charged Eafford with possession of cocaine, and the least degree of that offense is a felony of the fifth degree; (2) the evidence presented at trial proved Eafford possessed cocaine; (3) the trial court instructed the jury that it could find Eafford guilty only if it found the drug involved to be cocaine; and (4) the jury, which found Eafford guilty as charged in the indictment, thus found him guilty of possession of cocaine as a felony. . View "State v. Eafford" on Justia Law

Reporters for the Cincinnati Enquirer requested that the Cincinnati police department provide the newspaper with certain records related to a shootout at a local bar, including the names of the two police officers shot, their personnel files, and an unredacted copy of the incident report of the shootout. The Cincinnati police chief denied the requests insofar as the newspaper sought names and identifying information regarding the officers involved in the shootout. The Enquirer subsequently filed a complaint for a writ of mandamus to compel the police chief to make the requested records available for inspection and copying and seeking attorney fees. The court of appeals denied the writ and the request for attorney fees. The Supreme Court affirmed, holding that the court of appeals did not in denying the writ and request for attorney fees, as the requested identifying information of the police officers wounded in the shooting was exempted from disclosure under the Public Records Act by the constitutional right of privacy. View "State ex rel. Cincinnati Enquirer v. Craig" on Justia Law

Appellant Wesley Lloyd was convicted in Texas of aggravated sexual assault. Lloyd subsequently moved to Ohio. Lloyd was later convicted of several charges relating to his failure to register as a sex offender. The Supreme Court reversed, holding (1) the offense for which Appellant was convicted in Texas was a sexually oriented offense under Ohio law because it is substantially equivalent to rape, a listed Ohio offense, and therefore, Appellant's offense triggered a duty to register in Ohio; but (2) because the State failed to prove that at the time Appellant moved to Ohio, he was under a duty to register in Texas as a result of his conviction for aggravated sexual assault, Appellant's convictions must be vacated. View "State v. Lloyd" on Justia Law

This appeal involved two criminal cases against Mario Harris. In Harris I, Harris pleaded guilty to two offenses with forfeiture specifications. After the trial court imposed a sentence, Harris filed a motion for resentencing, which the court denied. The appellate court held that the trial court's denial of Harris's motion was not a final, appealable order because the sentencing court had failed to include the terms of forfeiture in the judgment of conviction. In Harris II, Harris pled guilty to an offense with an automobile-forfeiture specification. The trial court imposed a prison sentence and ordered the forfeiture. The court denied Harris's subsequent motion for resentencing. The appellate court held that the sentence was void because the trial court had failed to include a mandatory driver's license suspension as part of Harris's sentence. The Supreme Court consdoliated the cases and held (1) a journal entry of conviction need not include a related forfeiture in order to be a final appealable order; and (2) when a trial court fails to impose a mandatory driver's license suspension as part of an offender's sentence, that part of the sentence is void, and resentencing is limited to the imposition of the statutorily mandated term. View "State v. Harris" on Justia Law

Appellant, inmate Sidney Souffrance, petitioned the court of appeals for a writ of mandamus to compel Appellee, the records custodian for the Life Skills Center of Cincinnati, a community school, to provide access to the attendance records, addresses, and telephone numbers of all students who were in a certain classroom during two specific months and to records indicating which computer terminal a specific student had used during one of those months. The court of appeals held that the disclosure of the requested records was barred by the Family Educational Rights and Privacy Act (FERPA). The Supreme Court affirmed, holding that although the record request related to persons who were no longer students, because the persons were students when the records were created and originally maintained, the records were subject to the nondisclosure provisions of FERPA. View "State ex rel. Souffrance v. Doe" on Justia Law

County Commissioners passed a resolution establishing an early retirement incentive plan (ERIP). The resolution made the plan available to all employees of Commissioners except for the sanitary engineering division. A few days before passage of the resolution, some employees of the division filed a grievance regarding eligibility for the retirement plan. None of them were members of Union, a bargaining unit of employees who worked for the sanitary engineering division, but at least four Union members attended the hearing. The county administrator determined that the division employees were not permitted to participate in the retirement plan. Union filed a taxpayer action against Commissioners, on behalf of all union-member division employees, seeking a declaration that the ERIP was in violation of Ohio Rev. Code 145.297. The trial court agreed and held for Union. The court of appeals affirmed. The Supreme Court reversed, holding (1) Union lacked standing to bring a taxpayer action against Commissioners, and to the extent that Union had standing in its own right, Union failed to exhaust its administrative remedies; and (2) therefore, the issue of whether Commissioners' ERIP was in violation of section 145.297 was moot. View "State ex rel. Teamsters Local Union v. Bd. of Comm'rs" on Justia Law