Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court denying Petitioner's request for injunctive and declaratory relief claiming that the application of Ohio Rev. Code 2969.271 to his conduct violated his rights under the First and Fourteenth Amendments to the United States Constitution, holding that the lower courts erred.Section 2969.271 allows the Ohio Department of Rehabilitation (DRC) and Correction to administratively extend an incarcerated defendant's prison term beyond his minimum prison term or presumptive earned early-release date but not beyond his maximum prison term. Petitioner entered Alford pleas to attempted burglary and other offenses. The trial court imposed a sentence under the "Reagan Tokes Law." On appeal, Petitioner argued that the sections of the statute allowing DRC to extend his prison term beyond the presumptive minimum term was unconstitutional. The court of appeals concluded that Petitioner's constitutional challenge was not ripe for review. The Supreme Court reversed, holding that a criminal defendant's challenge to the constitutionality of section 2969.271 is ripe for review on the defendant's direct appeal of his conviction and prison sentence. View "State v. Maddox" on Justia Law

The Supreme Court reversed the judgment of the court of appeals denying Appellant's application to reopen his appeal, holding that Appellant's application showed that there was a genuine issue of material fact as to whether he was deprived of the effective assistance of appellate counsel.Appellant pleaded guilty to several sex-related offenses. On appeal, the court of appeals reasoned that, due to an incomplete record, it was compelled to presume regularity in the lower-court proceedings and affirmed the trial court's judgment. Represented by new appellate counsel, Appellant timely filed an application to reopen his direct appeal, asserting that his original appellate counsel's performance was deficient. The court of appeals denied the application. The Supreme Court reversed, holding that Appellant's application to reopen his appeal showed a genuine issue of ineffective assistance of appellate counsel warranting a reopening of the appeal. View "State v. Leyh" on Justia Law

The Supreme Court held that Petitioners showed beyond a reasonable doubt that the General Assembly-district plan adopted by the Ohio Redistricting Commission on January 22, 2022 violated Ohio Const. Art. XI, 6(A) and (B) and ordered the Commission to adopt a new plan.On January 12, 2022, the Supreme Court held that the General Assembly-district plan adopted by the Commission in September 2021 was invalid and that the Commission had not drawn a district plan that met neither of the standards set forth in sections 6(A) and 6(B) and ordered the Commission to adopt a new plan. On January 22, the Commission adopted a new plan. The Supreme Court again ordered the Commission to be reconstituted and to adopt yet a newer plan, holding that the new plan violated sections 6(A) and 6(B). View "League of Women Voters of Ohio v. Ohio Redistricting Comm." on Justia Law

The Supreme Court declared the congressional-district plan passed by the General Assembly invalid, holding that the General Assembly did not comply with Ohio Const. art. XIX, 1(C)(3)(a) and (b) in passing the plan and that a new congressional-district plan must be passed the complies in full with Article XIX and is not dictated by partisan considerations.At issue was 2021 Sub.S.B. No. 258, which was passed by a simple majority and signed into law by Governor Mike DeWine on November 20, 2021. The bill resulted in districts in which undue political bias was at least, if not more, likely to favor Republican candidates than the 2011 reapportionment that impelled Ohio's constitutional reforms. Petitioners argued that the congressional-district plan violated Article XIX, Section 1(C)(3)(a). The Supreme Court held that the congressional-district plan was invalid in its entirety because it unduly favored the Republican Party and disfavored the Democratic Party and because it unduly split three counties, in violation of Article XIX, Section 1(C)(3)(b). View "Adams v. DeWine" on Justia Law

The Supreme Court held that the General Assembly-district plan (the plan) adopted by the Ohio Redistricting Commission in September 2021 to be effective for the next four years was invalid under Ohio Const. art. XI, 6(A) and 6(B).The complaints in these three cases alleged that the plan was invalid because the Commission did not attempt to draw it to meet the standards of partisan fairness and proportionality. The Supreme Court agreed, holding that the plan was invalid because the Commission did not attempt to draw it to meet the proportionality standard in article XI, section 6(B) and did not attempt to draw it to met the standard in section 6(A) that no plan shall be drawn primarily to favor a political party. View "League of Women Voters of Ohio v. Ohio Redistricting Committee" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal concluding that a municipality does not violate Ohio Const. art. XVIII, 6 by selling a surplus of electricity to customers outside the municipality's boundaries, holding that the court of appeals did not err.The City of Cleveland sold outside its boundaries approximately four percent of the electricity it sold inside its boundaries. Cleveland Electric Illuminating Company (CEI) brought this complaint arguing that the electricity the City sold extraterritorially as surplus violated this Court's decision in Toledo Edison Co. v. Bryan, 737 N.E.2d 529 (2000) and the Ohio Constitution. The trial court granted summary judgment for the City. The court of appeals reversed, determining (1) Article XVIII, Section 6 does not require a municipality to buy the precise amount of electricity required by its inhabitants at any given time, and (2) questions of material fact existed as to whether the City obtained surplus electricity for the sole purpose of selling it to a neighboring city. The Supreme Court affirmed, holding that while a municipality may not acquire excess capacity for the sole purpose of reselling it outside the municipality's territorial boundaries, the municipality is not required to purchase the exact amount of electricity necessary to satisfy the current needs of its territorial customers. View "Cleveland Electric Illuminating Co. v. Cleveland" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition against Appellees - Judge Dale A. Crawford and the Hocking County Common Pleas Court - but affirmed the denial of her motion for disqualification of attorney Randall L. Lambert, holding that the court of appeals erred in part.Appellant was found guilty of assaulting a police officer. At a sentencing hearing at which Appellant appeared without counsel, Appellant refused to sign a waiver-of-counsel form. Judge Crawford conducted the sentencing hearing, at the end of which he imposed a six-month sentence in the county jail and ordered Defendant to pay a fine, restitution, and court costs. Appellant filed a complaint for writs of mandamus and prohibition alleging that Judge Crawford lacked jurisdiction to hold the sentencing hearing because she had not waived her right to counsel. The court of appeals dismissed the complaint and denied the motion to disqualify Lambert. The Supreme Court reversed in part, holding that Appellant stated a colorable claim that Judge Crawford violated her Sixth Amendment rights when he ordered her to not communicate with any lawyer and then sentenced her and that this error rendered the sentencing entry void. View "State ex rel. Ogle v. Hocking County Common Pleas Court" on Justia Law

The Supreme Court held that neither a showing of exigent circumstances nor a showing of the impracticability of obtaining an arrest warrant is necessary to sustain the constitutionality of a warrantless arrest under either the Ohio Constitution or the United States Constitution.Defendant was convicted of multiple drug offenses. On appeal, Defendant challenged the trial court's denial of his motion to suppress, arguing that his arrest was unlawful because there were no exigent circumstances to justify a warrantless arrest. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a warrantless arrest based on probable cause and conducted in public is reasonable under the Fourth Amendment; (2) neither exigent circumstances nor the impracticability of obtaining a warrant is required to justify a warrantless felony arrest that is supported by probable cause and that is conducted in public; and (3) the arrest in this case was constitutionally valid. View "State v. Jordan" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that the Retroactivity Clause of the Ohio Constitution prohibits the state from applying "Sierah's Law," Ohio Rev. Code 2903.41 through 2903.44, to an offender whose criminal conduct occurred prior to the legislation's effective date, holding that this Court's determination in State v. Hubbard, __ N.E.3d __ (Ohio 2021), was dispositive of this case.Sierah's Law, which created a violent offender database, became effective March 20, 2019. Appellant in this case pleaded guilty on March 4, 2019 to several crimes. At a sentencing hearing on April 1, 2019, Appellant was notified of his duty to register as a violent offender. The court of appeals reversed, concluding that the Retroactivity Clause prohibited the state from applying Sierah's Law to Appellant. The Supreme Court reversed, holding that, adhering to this Court's determination in Hubbard, the application of Sierah's Law to conduct that occurred prior to its effective date does not violate the Retroactivity Clause of Ohio Const. art. II, 28. View "State v. Jarvis" on Justia Law

The Supreme Court held that the application of "Sierah's Law," Ohio Rev. Code 2903.41 through 2903.44, to conduct that occurred prior to its effective date, does not violate the Retroactivity Clause of Ohio Const. art. II, 28.Seirah's Law presumptively requires offenders who are convicted of certain crimes to enroll in Ohio's "Violent Offender Database" for a period of ten years and presumptively requires an offender to enroll if he was convicted of any of those offenses or was serving a termination of confinement for the offense on or after the provisions' effective date. The court of appeals in this case determined that Sierah's Law does not affect a substantive right because it does not "impose a new burden in the constitutional sense" and therefore may be applied to conduct that occurred prior to its effective date. The Supreme Court affirmed, holding that the application of Sierah's Law to violent offenders who committed their offenses prior to its effective date does not violate the Retroactivity Clause of the Ohio Constitution. View "State v. Hubbard" on Justia Law