Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus for noncompliance with Ohio Rev. Code 2969.25(A) and remanded this case, holding that the record contained the required affidavit.Appellant, an inmate imprisoned for rape and other offenses, filed a petition for a writ of mandamus seeking an order compelling him to vacate the judgment of conviction because it was unsigned. The court of appeals dismissed the action based on Appellant's purported failure to file an affidavit of prior actions, as required by section 2969.25(A). The Supreme Court reversed, holding that the affidavit Appellant filed with his petition supported his argument that he complied with section 2969.25(A). View "State ex rel. Woods v. Jenkins" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting Appellant's petition for a writ of mandamus but denying his requests for statutory damages and court costs, holding that there was no error.Appellant, an inmate, sent a public-records request to Appellee, an employee of a private company that contracts with the state of Ohio to house state prisoners. Dissatisfied with the ultimate response, Appellant filed the current action asking for a writ of mandamus ordering Appellee to produce the records requested. The court of appeals granted the writ to a limited extent and denied Appellant's request for statutory damages and court costs. The Supreme Court affirmed, holding that the court of appeals did not err in denying Appellant's request for statutory damages and court costs. View "State ex rel. Atakpu v. Shuler" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of prohibition and mandamus against the Ohio Parole Board and the Franklin County Child Support Enforcement Agency (collectively, the State) and denied Appellant's motions to strike the State's merit brief in whole or in part, holding that there was no error.Appellant was found guilty, after a jury trial, of the rape of two women, one of whom he impregnanted, kidnapping, and attempted rape. Appellant subsequently appeared before the parole board eight times and was denied parole each time. Appellant later filed an original action of writs of prohibition and mandamus arguing that the parole board improperly denied parole. The court of appeals dismissed the complaint for failure to state a claim. The Supreme Court affirmed and denied Appellant's motions to strike, holding that Appellant failed to establish that he was entitled to relief. View "State ex rel. Dodson v. Ohio Dep't of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the Tenth District Court of Appeals denying Appellant's action seeking a writ of mandamus ordering the Ohio Parole Board to reinstate his parole and hold a new revocation hearing, holding that there was no error.Appellant was released on parole in 2019 after his incarceration for murder and other crimes. He was subsequently arrested for violating the terms of his parole. After a hearing, the Ohio Parole Board revoked Appellant's parole, finding that he had engaged in sexual contact with a woman without her consent. The Tenth District denied Appellant's subsequent petition seeking a writ of mandamus ordering the parole board to reinstate his parole and hold a new revocation hearing. The Supreme Court affirmed, holding that Appellant did not show by clear and convincing evidence that he was entitled to a writ of mandamus. View "State ex rel. Cartwright v. Ohio Adult Parole Bd." on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus to compel the common pleas court judge who sentenced him to correct what he alleged was an illegal sentence, holding that a court must give the parties notice and an opportunity to be heard before taking notice of facts contained in another court's dockets and relying on those facts to sua sponte dismiss a complaint for failure to comply with Ohio Rev. Code 2969.25.Appellant filed a complaint for a writ of mandamus arguing that his sentence for attempted murder with specifications was unlawful. The court of appeals sua sponte dismissed the complaint on the grounds that Appellant had failed to comply with section 2969.25(A). The Supreme Court reversed, holding that the court of appeals erred by consulting the record of another case in another court to determine the accuracy of Appellant's section 2969.25(A) and by dismissing Appellant's complaint based on information it obtained without first giving him notice and an opportunity to be heard. View "State ex rel. Roush v. Hickson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's complaint for a writ of habeas corpus against the warden of the Madison Correctional Institution, holding that the court of appeals correctly denied Appellant's petition for a writ of habeas corpus.Appellant was convicted of rape, felonious sexual penetration, and gross sexual imposition. Appellant later filed the complaint for a writ of habeas corpus at issue in this case, alleging that the trial court had sentenced him for an offense when it lacked jurisdiction to do so and, alternatively, that the trial court failed to impose a judgment that satisfied the requirements of Crim.R. 32. The court of appeals denied the writ. The Supreme Court affirmed and denied Appellant's motion for transcripts and journal entires, holding that Appellant's propositions of law were either waived or that Appellant's remedy did not lie in habeas corpus. View "State ex rel. Haddix v. Warden" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus seeking release from custody on bail on reasonable conditions of bond, holding that habeas corpus was not the proper action by which to challenge the trial court's denial of bail.Appellant, who was being held without bail pending trial for rape and other charges, filed a verified complaint seeking a writ of habeas corpus ordering the Franklin County Sheriff Dallas Baldwin to release him from custody and "let him to bail" upon reasonable conditions of bond. The court of appeals granted the sheriff's motion to dismiss. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law by means of appeal from the denial of his requests for pretrial release on bail, thus excluding extraordinary relief in habeas corpus. View "State ex rel. Garcia v. Baldwin" on Justia Law

The Supreme Court denied Relator's complaint seeking a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction (DRC) to provide documents in response to submitted public records requests, holding that this action was moot.Relator, an inmate at the London Correctional Institution, sent several requests to the DRC for records and kites. DRC provided a requested record and concluded that the remaining records were electronic kites. Relator then made subsequent requests. The DRC denied the requests and ultimately gave Relator a formal directive to stop the repetitive requests. Relator then filed his mandamus complaint. The Supreme Court denied the writ and awarded Relator $1,000 in statutory damages, holding (1) Relator's requests for the kites were moot because the DRC provided all the requested kites; and (2) Relator was entitled to statutory damages. View "State ex rel. Straughter v. Ohio Dep't of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against the warden of the Trumbell Correctional Institution, where Appellant was serving a forty-year prison sentence, holding that there was no error.Appellant was serving his prison sentence for nine convictions for felonious assault, in violation of Ohio Rev. Code 2903.11(B)(3). Appellant filed a petition for a writ of habeas corpus arguing, inter alia, that section 2903.11(B)(3) violates the Equal Protection Clauses of the Ohio and United States Constitution. The court of appeals dismissed the petition for failure to state a valid claim for habeas relief. The Supreme Court affirmed, holding that habeas corpus did not lie for Appellant's nonjurisdictional claims. View "Christian v. Davis" on Justia Law

The Supreme Court remanded this case to the trial court for it to enter a judgment of conviction against Appellant for criminal trespass under Ohio Rev. Code 2911.21(A)(1) and to sentence him in accordance with this opinion, holding that insufficient evidence supported Appellant's conviction of burglary.Under Ohio Rev. Code 2911.12(A)(2), the State was required to prove that Appellant trespassed by "force, stealth, or deception" in order to convict him of burglary. The court of appeals affirmed the conviction. The Supreme Court reversed and vacated Appellant's burglary conviction and judicial sanction, holding (1) to prove a defendant trespassed by stealth or deception in a burglary case the State must prove that the defendant actively avoided discovery or used deceptive conduct to gain entry to the structure; and (2) the evidence in this case was insufficient to convict Appellant of burglary but sufficient to convict him of criminal trespass. View "State v. Bertram" on Justia Law