Justia Ohio Supreme Court Opinion Summaries

A jury found Jack Carlisle guilty of kidnapping and gross sexual imposition (GSI) and sentenced him to three years' imprisonment for kidnapping and one year of imprisonment for GSI, to be served concurrently. The trial court later vacated Carlisle's sentence due to change of circumstances, namely the cost of Carlisle's dialysis, and imposed a sentence of five years of community control. The court of appeals reversed, concluding that the trial court lacked authority to modify Carlisle's sentence because his convictions had been affirmed on appeal. The Supreme Court affirmed but on different grounds, holding that the trial court in this case lacked the requisite authority to modify Carlisle's sentence, as absent statutory authority, a trial court is generally not empowered to modify a criminal sentence by reconsidering its own final judgment. Remanded. View "State v. Carlisle" on Justia Law

A three-judge panel convicted Lamont Hunter for the aggravated murder and rape of a three-year-old and child endangerment. The panel sentenced Hunter to death based on two death-penalty specifications: aggravated murder while committing or attempting to commit rape and aggravated murder of a child under the age of thirteen. The Supreme Court affirmed Hunter's convictions and sentence of death, holding (1) Hunter did not meet his burden of demonstrating that his counsel rendered ineffective assistance; (2) the trial court did not abuse its discretion in admitting evidence that Hunter had previously abused the child; (3) the panel did not create a miscarriage of justice in convicting Hunter of all counts and specifications; (4) the panel did not err in denying multiple defense motions; (5) the panel did not err in sentencing Hunter to consecutive sentences for his noncapital offenses in violation of his constitutional rights; and (6) the aggravating factors clearly outweighed any mitigating factors beyond a reasonable doubt, and the penalty imposed in this case was appropriate and proportionate when compared to death sentences approved for other rape-murders. View "State v. Hunter" on Justia Law

After Appellant Jermaine McKinney was convicted and sentenced in a criminal case, Appellant petitioned for writs of mandamus and procendendo to compel Appellee, a county court of common pleas judge, to issue a final, appealable order in his criminal case. The court of appeals dismissed the petition. The Supreme Court affirmed, holding (1) the judge's sentencing entry in the criminal case fully complied with Ohio. R. Crim. P. 32(C) by including the findings of the jury upon which Appellant's convictions were based, the sentence, the signature of the judge, and the clerk's time stamp; and (2) Appellant had an adequate remedy by appeal to raise the claim that the judge erred in his sentencing entry. View "State ex rel. McKinney v. McKay" on Justia Law

Relator, Angela Dawson, requested a writ of mandamus to compel Respondent, a local school district, to provide her with access to (1) itemized invoices of law firms providing services to the district in matters pertaining to Dawson and her children, and (2) communications from the school district's insurance carrier identifying the district's legal representative and describing the liability and exposure of the district and insurance company related to a case filed against the district by Dawson on behalf of one of her children. The Supreme Court denied the writ, holding that the requested records were exempt from disclosure under the Public Records Act because the school district met its burden of establishing the applicability of the attorney-client privilege to the requested records. View "State ex rel. Dawson v. Bloom-Carroll Local Sch. Dist." on Justia Law

Anthony Belton was charged with aggravated murder with death-penalty specifications and aggravated robbery with firearm specifications. Belton filed a motion challenging the constitutionality of Ohio Rev. Code 2929.03 and Ohio R. Crim. P. 11(C)(3), claiming these provisions were unconstitutional because they precluded him from entering a guilty plea without waiving his right to a jury trial during the sentencing phase of his capital case. The common pleas court denied the motion and upheld the provisions as constitutional. Belton later filed a motion for leave to file a delayed appeal from the common pleas court's order. The court of appeals granted the motion. The State subsequently filed an action for a writ of prohibition to prevent the court of appeals from proceeding in Belton's delayed appeal and to compel dismissal of the appeal. The Supreme Court granted the writ, holding that the court of appeals patently and unambiguously lacked jurisdiction to proceed with the appeal when the order did not constitute a final, appealable order. View "State ex rel. Bates v. Court of Appeals " on Justia Law

Appellant Carlos Galloway filed requests for writs of mandamus and procedendo to compel Appellees, the county court of common pleas and its judge, to issue judgments in Appellant's criminal cases that complied with Ohio R. Crim. P. 32(C) and constituted final, appealable orders. The court of appeals denied Appellant's request. The Supreme Court affirmed, holding (1) the sentencing entries in Appellant's criminal cases fully complied with rule 32(C); (2) insofar as Appellant's claimed that one of his sentencing entries did not properly reflect the jury's verdict, he raised mere error and had an adequate remedy by appeal to raise the issue; and (3) any error regarding the imposition of court costs could be challenged by appeal. View "State ex rel. Galloway v. Lucas County Court of Common Pleas" on Justia Law

Relators, Ohioans for Fair Districts and its members, petitioned the Supreme Court for a writ of mandamus to compel Respondent, Secretary of State Jon Husted, to treat Sections 1 and 2 of H.B. 319, which established new congressional districts for the state based on the 2010 decennial census, as subject to referendum, to accept the submission of Relators' referendum-petition summary, and to discharge the duties of Husted's office as provided by Ohio Const. art. II and Ohio Rev. Code 3519.01. The Supreme Court granted the writ, holding (1) the writ was consistent with precedent and the plain language of Ohio Const. art. II, and (2) unless a valid referendum petition was timely filed with the secretary of state, H.B. 319 would become effective ninety days from the date the bill was filed by the governor in the office of the secretary of state. View "State ex rel. Ohioans for Fair Dists. v. Husted" on Justia Law

After a jury trial, Appellant was found guilty of various crimes. The judgment entry of conviction did not set out whether the conviction was based upon a guilty or no-contest plea or upon a bench trial or jury trial. The cause was remanded for resentencing for other reasons. On remand, the judgment entry contained the same error. The trial court then sua sponte filed a nunc pro tunc judgment entry supplementing the wording of the original resentencing judgment entry. The appellate court sua sponte dismissed the appeal for lack of jurisdiction, finding no new or substantial right was affected by correction of the sentencing judgment. Appellant subsequently obtained a certification of a conflict of the decision in this case with that of State v. Lampkin. At issue on appeal was whether a nunc pro tunc judgment entry that is issued solely to correct a clerical omission in a prior final judgment entry constitutes a new final order from which a new appeal may be taken. The Supreme Court affirmed, holding that no new right of appeal is created by such an entry, and therefore, the entry in this case was not a final order from which an appeal could be taken. View "State v. Lester" on Justia Law

A jury convicted Roland Davis of aggravated murder, murder, kidnapping, aggravated burglary, and aggravated robbery. Davis was sentenced to death. The trial court dismissed Davis's petition for postconviction relief, and the court of appeals affirmed. Davis then filed a motion for a new trial based upon newly discovered evidence. The trial court denied the motion. The court of appeals affirmed, holding that the trial court did not err because the trial court lacked jurisdiction to act on a motion for a new trial. The Supreme Court reversed the appellate court, holding (1) a trial court has jurisdiction over a motion for a new trial based on newly discovered evidence when the specific issue has not been decided on direct appeal; and (2) an appellate court has jurisdiction, in a case in which a death penalty has been imposed, to consider the trial court's denial a motion for a new trial based on newly discovered evidence. View "State v. Davis" on Justia Law

Travis Carpenter, a Clinton Township police officer, was involved in a motor vehicle accident outside his own jurisdiction while responding to a general dispatch call for assistance from an officer in another jurisdiction. The passenger in the vehicle that collided with Carpenter's vehicle filed a personal-injury suit naming as defendants, inter alia, Carpenter and Clinton Township. The trial court granted summary judgment to Carpenter and Clinton Township, concluding that they were entitled to immunity under Ohio Rev. Code 2744 because Carpenter was on an emergency call for purposes of the statute as he had a professional obligation to respond to the dispatch. The appellate court affirmed. The Supreme Court affirmed, holding that Carpenter could be considered to have been on an emergency call at the time of the accident for purposes of chapter 2744 when the evidence was insufficient to establish the existence of a mutual-aid agreement between the jurisdictions because application of the immunity statutes in this case did not depend on whether a mutual-aid agreement existed. View "Smith v. McBride" on Justia Law