Justia Ohio Supreme Court Opinion Summaries

A woman was killed in her Cincinnati apartment on July 31, 2019, after returning home with groceries and a purse. She was attacked in the entryway and strangled with her purse strap. Later that day, her son was stopped by law enforcement in Indiana while driving her car and found in possession of her wallet, which contained her identification, credit cards, and a recent grocery receipt. The son had left his aunt’s home in Georgia days earlier without permission, taking her car, which was later found near the victim’s apartment. Evidence showed the son had traveled from Georgia to Ohio, and surveillance footage placed him near the victim’s home the night before the murder. The victim had been trying to locate her son, believing he was still in Georgia.The Hamilton County Court of Common Pleas convicted the son of two counts of aggravated murder, aggravated robbery, tampering with evidence, and receiving stolen property. The trial court suppressed some of the son’s custodial statements but admitted others, as well as testimony about his prior acts. The First District Court of Appeals found that the trial court erred by admitting certain custodial statements and other-acts evidence, and held these errors were not harmless. It reversed the convictions for aggravated murder, aggravated robbery, and tampering with evidence, finding insufficient evidence for tampering and barring retrial on that count, but allowed retrial on the other charges.The Supreme Court of Ohio reviewed the case and held that, even after removing the erroneously admitted evidence, the remaining evidence overwhelmingly established the son’s guilt for aggravated murder and aggravated robbery beyond a reasonable doubt. The court found the trial court’s errors harmless and reversed the appellate court’s judgment, reinstating the convictions for aggravated murder and aggravated robbery. The court also concluded that the convictions were not against the manifest weight of the evidence. View "State v. Roberts" on Justia Law

The defendant was indicted in Cuyahoga County, Ohio, on two counts of rape and one count of sexual battery involving a coworker. After a night out, the alleged victim claimed that she awoke in the defendant’s home to find him having intercourse with her. At trial, the defendant moved for judgment of acquittal, arguing that the state had failed to prove the offenses occurred in Cuyahoga County, thus failing to establish venue. The trial court granted the motion based on insufficient evidence of venue and entered a judgment of acquittal.The State of Ohio appealed the trial court’s decision to the Eighth District Court of Appeals both as of right and by seeking leave to appeal. The defendant argued that, under the Supreme Court of Ohio’s prior decision in State v. Hampton, the state could not appeal a judgment of acquittal based on lack of venue. The Eighth District dismissed both appeals in brief entries, relying on Hampton.The Supreme Court of Ohio reviewed the case and overruled its prior decision in State v. Hampton. The court held that venue is not an element of a criminal offense, and a judgment terminating a prosecution based on insufficient evidence of venue is not a judgment of acquittal but rather a dismissal of the indictment, complaint, or information. Therefore, under R.C. 2945.67(A), the state has a right to appeal such a dismissal as of right. The Supreme Court of Ohio reversed the Eighth District’s judgment dismissing the state’s appeal as of right and remanded the case for further consideration. The court affirmed the dismissal of the state’s discretionary appeal as unnecessary. View "State v. Musarra" on Justia Law

A prisoner who was serving a sentence for multiple felony offenses believed that the Ohio Department of Rehabilitation and Correction had miscalculated the length of his prison term. Initially, the department determined his sentence to be 11 years, but before his anticipated release, it recalculated the sentence as 13 years. After his original release date passed, the prisoner filed a habeas corpus petition, arguing that his maximum sentence had expired and he was being unlawfully held. The trial court found the sentencing entry ambiguous regarding the sentence length, resolved the ambiguity in the prisoner’s favor, and ordered his immediate release.The warden requested a stay of the trial court’s order, which was denied. The warden then appealed to the Ninth District Court of Appeals and again sought a stay, but the appellate court denied the request due to a procedural deficiency. Without addressing the merits of the appeal, the Ninth District dismissed the case as moot, reasoning that the prisoner’s release and the warden’s failure to secure a stay rendered the appeal moot.The Supreme Court of Ohio reviewed the case to determine whether the prisoner’s release rendered the warden’s appeal moot. The court held that the appeal was not moot because, if the warden prevailed, the prisoner could be returned to custody to serve the remainder of his sentence. The court explained that an actual controversy remained, as effective relief could still be granted. The Supreme Court of Ohio reversed the judgment of the Ninth District Court of Appeals and remanded the case for consideration of the merits of the warden’s appeal. View "Maurent v. Spatny" on Justia Law

The case concerns a defendant who was convicted by a jury of multiple sexual offenses, including rape, against his young daughter. The central issue on appeal relates to the jury selection process, specifically whether the defendant’s trial counsel was constitutionally ineffective for failing to challenge a particular juror, referred to as Juror McCarthy, for cause. During voir dire, Juror McCarthy expressed some initial uncertainty about his ability to be impartial in a case involving a child witness and indicated discomfort with the presumption of innocence, but also participated in group responses affirming his willingness to be fair and follow the law.After conviction, the defendant appealed to the Twelfth District Court of Appeals, arguing that his counsel’s failure to challenge Juror McCarthy deprived him of a fair trial. The appellate court reviewed the voir dire transcript and concluded that Juror McCarthy’s statements reflected an internal struggle common to many jurors faced with difficult subject matter, rather than actual bias against the defendant. The court also noted that Juror McCarthy, through group responses and direct questioning, indicated he could be fair and impartial. The appellate court therefore rejected the ineffective assistance claim and affirmed the convictions.The Supreme Court of Ohio reviewed the case, focusing on whether a reviewing court may consider group answers during voir dire when determining actual juror bias, and whether a juror who expresses partiality can be rehabilitated through such group responses. The court held that, in assessing actual bias, the entire voir dire record—including group answers—must be considered. The court found that the defendant failed to demonstrate that Juror McCarthy was actually biased, and thus did not establish ineffective assistance of counsel. The Supreme Court of Ohio affirmed the judgment of the Twelfth District Court of Appeals. View "State v. Rogers" on Justia Law

The case concerns a defendant who was charged with multiple counts of rape and gross sexual imposition involving a minor. He pleaded guilty to several counts, after which his defense counsel withdrew and new counsel was appointed. Despite being represented, the defendant filed several motions on his own, including a motion to withdraw his pleas and a motion to represent himself. The trial court allowed him to represent himself but denied his motion to withdraw his pleas. Before sentencing, he requested and was granted new counsel, and was ultimately sentenced to concurrent prison terms.The defendant appealed to the Ninth District Court of Appeals, arguing, among other things, that the trial court failed to obtain a proper waiver of counsel. The appellate court agreed, finding that the trial court erred in accepting the waiver and failed to comply with procedural requirements, so it reversed and remanded. On remand, the trial court determined that the guilty pleas remained valid and resentenced the defendant. The defendant appealed again, but the appellate court affirmed the trial court’s decision. He then filed an application to reopen his appeal under Ohio Appellate Rule 26(B), claiming ineffective assistance of appellate counsel. The Ninth District granted the application but later confirmed its prior judgment, finding that the defendant had not adequately addressed how his prior appellate counsel was deficient or how he was prejudiced by that deficiency.The Supreme Court of Ohio reviewed whether an appellate court may presume ineffective assistance of counsel in a reopened appeal when the appellant fails to specifically argue counsel’s deficiency and resulting prejudice, as required by App.R. 26(B)(7). The court held that the requirements of App.R. 26(B)(7) are mandatory: an appellant must address both the deficiency of prior appellate counsel and the resulting prejudice in their brief. Because the defendant failed to do so, the Supreme Court of Ohio affirmed the judgment of the Ninth District Court of Appeals. View "State v. Clark" on Justia Law

A city filed a criminal complaint against a property owner, alleging that his property was in violation of certain provisions of the International Property Maintenance Code (IPMC), which the city had adopted by ordinance. The complaint stated that the property’s residence lacked water service, had holes in the roof, and that a break wall was collapsing into a river. It also alleged the presence of various items described as “debris,” such as barrels, lawn mowers, boats, trailers, propane tanks, and overgrown vegetation. The city claimed these conditions violated IPMC sections requiring properties to be maintained in a “clean,” “safe,” and “sanitary” condition.The property owner moved to dismiss the charges in the Huron Municipal Court, arguing that the IPMC provisions were unconstitutionally vague because the terms “clean,” “safe,” and “sanitary” were undefined. The trial court agreed, relying on a prior decision from the Seventh District Court of Appeals, State v. ACV Realty, which had found similar IPMC language void for vagueness. As a result, the trial court dismissed the relevant counts. The city appealed, and the Sixth District Court of Appeals reversed, holding that the terms in question should be given their ordinary meanings and were sufficiently clear to inform property owners of the prohibited conduct.The Supreme Court of Ohio reviewed the case to resolve a conflict between appellate districts. The court held that a defendant cannot successfully challenge a law as void for vagueness if his conduct clearly falls within the activities the law prohibits. Because the alleged conditions of the property—such as lack of water, structural decay, and accumulation of debris—clearly violated the IPMC provisions, the property owner’s vagueness challenge failed. The Supreme Court of Ohio affirmed the appellate court’s judgment and remanded the case to the municipal court for further proceedings. View "Huron v. Kisil" on Justia Law

The case concerns an individual who pleaded guilty in 2004 to two counts of forgery, both fifth-degree felonies, after depositing counterfeit checks and withdrawing funds from a credit union. The trial court sentenced him to concurrent nine-month prison terms and ordered him to pay $2,663 in restitution to the victim, Mid-State Credit Union, and $408 in court costs. The sentencing entry specified that these amounts were entered as civil judgments. After serving his sentence and completing postrelease control, the individual applied in 2022 to have the record of his convictions sealed, though he had not paid the restitution.The Franklin County Court of Common Pleas granted the application to seal the records, despite the State’s objection that restitution remained unpaid. The State appealed, but the Tenth District Court of Appeals affirmed the trial court’s decision. The appellate court reasoned that because the restitution was entered “as a civil judgment,” it was not a criminal sanction that needed to be satisfied before the record could be sealed. The court further concluded that the civil judgment for restitution had become permanently dormant under debtor-protection laws, as it had not been revived within the statutory period.The Supreme Court of Ohio reviewed the case and held that, regardless of how a restitution order is labeled in a sentencing entry, it remains a criminal sanction that is part of the sentence. Therefore, restitution must be paid before an offender is eligible to apply to have the record of conviction sealed. The court reversed the judgment of the Tenth District Court of Appeals and remanded the case for consideration of the individual’s constitutional arguments. View "State v. T.W.C." on Justia Law

In 1996, the defendant pleaded guilty to several first-degree felonies, including rape, attempted aggravated murder, kidnapping, and aggravated burglary, for acts committed in 1995. The trial court imposed an aggregate indefinite prison sentence of 15 to 50 years under the sentencing laws in effect before July 1, 1996. Over the years, the defendant challenged aspects of his sentence and conviction, including the indefinite nature of his sentence and the lack of eligibility for judicial release, but these challenges were unsuccessful.After serving more than 26 years, the defendant filed a motion for judicial release under R.C. 2929.20 in December 2021, arguing that he was serving a “stated prison term” and had completed the mandatory portion of his sentence. The State of Ohio opposed the motion, asserting that the defendant was serving an indefinite sentence under pre-S.B. 2 law and was therefore ineligible for judicial release. The trial court granted the motion for judicial release, placing the defendant on community control, and the State appealed. The Seventh District Court of Appeals affirmed, reasoning that amendments to R.C. 2929.20 had expanded eligibility for judicial release to include offenders serving nonmandatory sentences on or after April 7, 2009.The Supreme Court of Ohio reviewed the case and held that the definition of “eligible offender” for purposes of judicial release under R.C. 2929.20 includes only those serving a “stated prison term,” as defined in R.C. 2929.01. The court concluded that an offender serving an indefinite sentence imposed under pre-S.B. 2 law does not meet this definition and is therefore not eligible for judicial release. The Supreme Court of Ohio reversed the judgment of the Seventh District Court of Appeals and remanded the case to the trial court to deny judicial release. View "State v. Staffrey" on Justia Law

A resident of Lucas County, along with his nephews, was involved in a drug-selling enterprise known as the Tecumseh Street Gang, which operated primarily on the 800 block of Tecumseh Street in Toledo. The group was a subset of a larger gang, the Southside Gangster Disciples. Law enforcement, using a confidential informant, discovered that a woman named Armijo was distributing cocaine for the Tecumseh Street Gang. On several occasions, Armijo purchased cocaine from one of the nephews in Lucas County and then traveled to Henry County to resell the drugs. She often bought the drugs on credit, keeping a portion of the profits after paying the supplier.The defendant was charged in the Henry County Court of Common Pleas with engaging in a pattern of corrupt activity. At trial, he argued that venue was improper in Henry County because Armijo was not part of the same enterprise. The trial court denied his motion for acquittal, and the jury found him guilty, also finding that venue was proper. On appeal, the Third District Court of Appeals upheld the conviction, concluding that the evidence supported the finding that Armijo was associated with the same enterprise and that her activities in Henry County established proper venue.The Supreme Court of Ohio reviewed the case to determine whether venue in Henry County was appropriate for prosecuting the defendant under R.C. 2923.32. The court held that venue was proper in any county where a member of the enterprise conducted activity on behalf of the enterprise, even if the defendant himself did not act there. The court found sufficient evidence that Armijo was associated with the enterprise and that her drug sales in Henry County were part of its activities. The Supreme Court of Ohio affirmed the judgment of the Third District Court of Appeals. View "State v. Brown" on Justia Law

A man who had attended elementary school with a woman, but had never been friends or even acquaintances with her, began contacting her more than a decade later. The woman, A.P., posted on her public Instagram account for her 29th birthday, and the man, Dorian Crawl, commented with a “sad emoji” and a message expressing affection and a desire to meet. A.P. did not respond. Days later, Crawl commented again on another post, asking if the video showed her house. Less than a month after these online interactions, Crawl appeared uninvited at A.P.’s apartment, knocked on her door, identified himself as her “friend,” and turned the doorknob. A.P., frightened, locked the door, hid her daughter, and called the police. Crawl later admitted to police that he had found A.P.’s address online and continued to message her even after being confronted by law enforcement. A.P. testified that these events caused her significant anxiety and changes to her daily life.The Miamisburg Municipal Court found Crawl guilty of menacing by stalking under R.C. 2903.211(A)(1). On appeal, the Second District Court of Appeals affirmed the conviction, holding that Crawl’s pattern of conduct—including the social media messages and the uninvited visit—along with A.P.’s testimony about her mental distress, was sufficient to support the conviction.The Supreme Court of Ohio reviewed the case and affirmed the judgment of the Second District Court of Appeals. The court held that, when viewing the evidence in the light most favorable to the prosecution, a rational trier of fact could find that the essential elements of menacing by stalking were proven beyond a reasonable doubt. The court clarified that explicit threats, a prior relationship, or notice from the victim are not required to establish the offense. The court concluded that Crawl’s actions constituted a pattern of conduct, caused mental distress, and were done knowingly. View "State v. Crawl" on Justia Law