Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the trial court finding Defendant guilty of kidnapping and rape and a repeat-violent-offender specification and imposing a ten-year sentence on each count, to be served concurrently, holding that the trial court denied Defendant his constitutional right to a fair jury as guaranteed by the Sixth and Fourteenth Amendments to the United States Constitution.At issue was whether Defendant's right to a fair trial was violated when the alleged victim was introduced to the jury as the State's designated representative and was permitted to sit at counsel table with the prosecutor during the proceedings. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court erred in designating the alleged victim as the State's representative and by allowing her to sit at the prosecutor's table and that the error was not harmless, requiring reversal. View "State v. Montgomery" on Justia Law

The Supreme Court determined that a warrantless search conducted in this case did not comport with the Fourth Amendment under the "single-purpose-container exception" to the warrant requirement, holding that when police search a bookbag in a home under circumstances that do not give rise to any exigency they must first obtain a warrant.After he was charged with illegal possession of drugs Defendant filed a motion to suppress, arguing that the warrantless search of the book bag conducted by a law enforcement officer was unlawful. The trial court denied the motion, concluding that the warrantless search was lawful because the book bag was in plain view and the officer had probable cause to suspect it contained contraband. The court of appeals affirmed. The Supreme Court reversed, holding (1) absent exigent circumstances, the search of a closed container requires a warrant; and (2) the single-purpose-container exception to the warrant did not apply in this case because a bookbag is not a single-purpose drug container. View "State v. Burroughs" on Justia Law

The Supreme Court dismissed this original action in which Relators sought a writ of mandamus against the Ohio State Senate and its thirty-three members individually, holding that this Court lacked jurisdiction to grant the relief sought.Relators sought a writ of mandamus to compel the House respondents to uphold Ohio Const. art. I, 21. The Supreme Court concluded that the request could be read either as a request to compel the House respondents to enact legislation prohibiting the practices to which Relators objected or as a request to prohibit the respondents from enacting legislation that would conflict with Article I, Section 21. The Supreme Court dismissed this action, holding that, under either theory, the relief sought was beyond the Court's jurisdiction to grant. View "State ex rel. Johnson v. Ohio State Senate" on Justia Law

The Supreme Court dismissed this original action in which Relators sought a writ of mandamus against the Ohio House of Representatives and ninety-eight of members individually, holding that this Court lacked jurisdiction over the complaint.Relators sought a writ of mandamus to compel the House respondents to uphold Ohio Const. art. I, 21. The Supreme Court concluded that the request could be read either as a request to compel the House respondents to enact legislation prohibiting the practices to which Relators objected or as a request to prohibit the respondents from enacting legislation that would conflict with Article I, Section 21. The Supreme Court dismissed this action, holding that, under either theory, the relief sought was beyond the Court's jurisdiction to grant. View "State ex rel. Jones v. Ohio House of Representatives" on Justia Law

The Supreme Court held that the General Assembly-district plan adopted by the Ohio Redistricting Commission on May 5, 2022 was invalid in its entirety and ordered the commission to draft and adopt an entirely new General Assembly-district plan that meets the requirements of the Ohio Constitution, including Article XI, Sections 6(A) and 6(B).On May 5, the Commission readopted the plan at issue, purportedly only for use in the 2022 election. The Supreme Court had earlier held the plan to be unconstitutional. Petitioners filed objections to the adoption of the plan. The Supreme Court sustained the objections, holding that the plan at issue was invalid in its entirety. View "League of Women Voters of Ohio v. Ohio Redistricting Commission" on Justia Law

The Supreme Court held that a reallocation of local-government funds regarding fines collected from the use of traffic cameras during the preceding fiscal year, called the "spending setoff," and the "deposit requirement" that municipalities file a civil action to enforce citations issued using traffic cameras to pay an advance deposit in the court are not unconstitutional.Appellees, municipalities that both operated programs to enforce their traffic laws with cameras, brought this action for a declaratory judgment and for injunction relief asserting that the "spending setoff" and the "deposit requirement" infringed on its municipal home rule powers, in violation of Ohio Const. art. XVIII, 3. Appellees requested a preliminary injunction, which the trial court denied. The court of appeals reversed, ruling that the spending setoff and deposit requirement unconstitutionally penalize municipalities for exercising their home-rule authority to enforce their traffic laws with cameras. The Supreme Court reversed, holding that neither the spending setoff nor the deposit requirement are unconstitutional. View "Village of Newburgh Heights v. State" on Justia Law

The Supreme Court affirmed Defendant's convictions for, among other crimes, two counts of aggravated murder with four death-penalty specifications attached to each count and Defendant's sentence of death, holding that there was no reversible error.Specifically, the Supreme Court held (1) Defendant's argument that the Ohio Constitution limits the right to self-representation was not well taken; (2) Defendant failed to show plain error as to his argument that his standby counsel interfered with his trial preparation and strategy; (3) the evidence was sufficient to support the convictions; (4) there was no abuse of discretion in jury selection; (5) the court did not admit inadmissible victim-impact testimony from witnesses during the trial phase or commit other reversible evidentiary error; (6) there was no prosecutorial misconduct or ineffective assistance of counsel; and (7) Defendant's remaining assignments of error were unavailing. View "State v. McAlpin" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus, holding that Appellant did not show that the parole-revocation proceedings violated his constitutional right to due process.Appellant was convicted of aggravated murder and aggravated robbery and was later released on parole. Appellant was subsequently charged with violating the terms of his parole. After a revocation hearing, the parole board approved the hearing officer's recommendation that Appellant be ordered to serve an additional thirty-six months in prison before again becoming eligible for parole. The parole board approved the recommendation. Appellant filed an action for a writ of mandamus alleging that he was denied the effective assistance of counsel and that reversible error occurred during the revocation hearing. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant failed to show that the parole revocation proceedings violated his constitutional right to due process. View "State ex rel. Mango v. Ohio Department of Rehabilitation & Correction" on Justia Law

For the fourth time this issue was before the Supreme Court, the Court held that the third-revised General Assembly-district plan adopted by the Ohio Redistricting Commission violates the standards of Ohio Const. art. XI, 6(A) and 6(B) and that a new plan must be adopted in conformity with the Ohio Constitution.Between September 2021 and February 2022 the Commission adopted three General Assembly-district plans, each of which the Supreme Court invalidated because they did not comply with Article XI, Sections 6(A) and 6(B). The Commission subsequently adopted its fourth plan - the third-revised plan. The Supreme Court ordered the Commission to be reconstituted and to adopt a new plan in conformity with the Ohio Constitution, holding that the third-revised plan violates Article XI, Sections 6(A) and 6(B). View "League of Women Voters of Ohio v. Ohio Redistricting Committee" on Justia Law

The Supreme Court held that the second revised General Assembly-district plan adopted by respondent Ohio Redistricting Commission violates Ohio Const. art. XI, sections 6(A) and 6(B) and ordered the Commission to be reconstituted.In the first time this issue was before the Supreme Court, the Court held that the Commission's original plan was invalid because the Commission had not attempted to meet the standards set forth in Article XI, Sections 6(A) and 6(B). The Commission subsequently adopted a revised plan, but the Supreme Court invalidated that plan because the Commission again had not satisfied sections 6(A) and 6(B). At issue now before the Supreme Court was the Commission's second revised plan. The Commission invalidated the plan in its entirety, holding that the second revised plan violates sections 6(A) and 6(B) and the a newly reconstituted Commission must adopt a new plan in conformity with the Ohio Constitution. View "League of Women Voters of Ohio v. Ohio Redistricting Commission" on Justia Law