Justia Ohio Supreme Court Opinion Summaries
Articles Posted in Criminal Law
State ex rel. Sultaana v. Mansfield Correctional Institution
The Supreme Court granted a writ compelling the Mansfield Correctional Institution to produce records requested by Relator against the Mansfield Correctional Institution under Ohio's Public Records Act, Ohio Rev. Code 149.43, holding that Relator was entitled to a writ.Relator requested information and records from the prison warden's office regarding three assaults committed against her son while he was incarcerated at the prison. After the prison asserted that all responsive records had been produced Relator brought this action. The Supreme Court granted the writ with respect to some of the requested records and granted a limited writ compelling the prison to produce additional requested records or to certify that no responsive records existed and denied Relator's motions to transfer this case to the court of claims, to strike the prison's merit brief, and other motions, holding (1) the prison failed to prove that certain withheld information fell squarely within an exception to the Act; (2) the prison did not carry its burden of proving that no other documents existed that were responsive to certain requests; and (3) Relator was not entitled to a writ of mandamus as to the remaining evidence. View "State ex rel. Sultaana v. Mansfield Correctional Institution" on Justia Law
Posted in:
Communications Law, Criminal Law
State ex rel. Bradford v. Bowen
The Supreme Court affirmed the judgment of the court of appeals denying a petition for a writ of habeas corpus sought by Appellant, holding that the court of appeals properly weighed the evidence.Appellant, Pele Bradford, filed a petition for a writ of habeas corpus alleging that his convictions for aggravated murder and other offenses were void because he was seventeen years old at the time of the offenses and not bound over from juvenile court. The Supreme Court reversed the court of appeals' decision granting summary judgment in favor of the warden because the court of appeals improperly considered a copy of a birth certificate attached to the warden's motion for summary judgment. On remand, the court of appeals denied the writ. On appeal, Appellant argued that the court of appeals "improperly consider[ed] the warden's return of the writ" and that a certain filing by the warden should have been stricken. The Supreme Court affirmed, holding that the court of appeals properly weighed the evidence after treating the warden's filing as a return of writ. View "State ex rel. Bradford v. Bowen" on Justia Law
Posted in:
Criminal Law
State ex rel. Norman v. Collins
The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus against the warden of the Pickaway Correctional Institution (PCI), where Appellant was an inmate, and denied Appellant's motion to supplement his merit brief with additional documents, holding that Appellant was not entitled to relief.According to Appellant, he was indicted in Franklin County for a crime that was committed in Fairfield County. Appellant filed a petition for a writ of habeas corpus asserting that Franklin County lacked venue or subject-matter jurisdiction. The court of appeals denied relief. The Supreme Court affirmed, holding that Appellant's petition failed to state a claim that is cognizable in habeas corpus. View "State ex rel. Norman v. Collins" on Justia Law
Posted in:
Criminal Law, Government & Administrative Law
State ex rel. Simpson v. Kirby
The Supreme Court granted a peremptory writ of prohibition compelling the probate-juvenile court to vacate its order granting the applications for immunity filed by two witnesses in a criminal case under Ohio Rev. Code 2945.44, holding that the probate-juvenile court patently and unambiguously lacked jurisdiction to grant the applications.Relator was charged with misdemeanor counts relating to her juvenile son, L.C. The prosecution filed an application in the county court seeking immunity for L.C. under section 2945.44, but the judge denied the application for want of jurisdiction. Thereafter, the prosecution filed an application in the probate-juvenile court requesting immunity for both L.C. and his stepbrother, M.R. The judge granted immunity to both witnesses. Relator then sought a writ of mandamus to compel the judge to vacate his order and a writ of prohibition. The Supreme Court granted a writ of prohibition in part and denied it in part and denied a writ of mandamus, holding the probate-juvenile court patently and unambiguously lacked jurisdiction to grant immunity under section 2945.44. View "State ex rel. Simpson v. Kirby" on Justia Law
Posted in:
Criminal Law
State ex rel. Justice v. State
The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's original action captioned “Petition for discharge for want of jurisdiction, judicial misconduct, and abuse of discretion, obstructions to justice, prosecutorial misconduct & perjury, & Brady rule violations, etc., effected pre-trial by respondents,” holding that the court of appeals did not err.In her complaint, which the court of appeals justice designated as an "appeal" from an earlier criminal judgment, Appellant argued that her speedy-trial rights had been violated, that the prosecution had withheld exculpatory evidence, and that the trial court had abused its discretion in various pretrial rulings. The court of appeals dismissed the complaint, concluding that it was insufficient to state a claim. The Supreme Court affirmed, holding that the court of appeals correctly dismissed the complaint for failure to state a claim within the jurisdiction of the court of appeals. View "State ex rel. Justice v. State" on Justia Law
Posted in:
Criminal Law
State ex rel. Ware v. Parikh
The Supreme Court granted in part and denied in part this action seeking a writ of mandamus ordering Hamilton County Clerk of Courts Pavan Parikh to provide copies of three oaths of office and various court records from a 2001 case and awards of statutory damages and costs, holding that Relator was entitled to mandamus in part.Relator, an inmate, sent a public records request requesting three judges' oaths of office and documents from a case filed in 2001. When the clerk of courts did not respond to the public-records request Relator filed this action. The Supreme Court granted relief in part, holding (1) Relator used the incorrect vehicle for requesting copies of the oaths of office; and (2) the clerk did not meet his burden to show that Ohio Rev. Code 149.43(B)(8) foreclosed Relator's right to receive the second portion of his records request. View "State ex rel. Ware v. Parikh" on Justia Law
Posted in:
Criminal Law, Government & Administrative Law
State ex rel. Martre v. Watson
The Supreme Court affirmed the judgment of the court of appeals denying Appellant's petition for a writ of habeas corpus against the warden of the North Central Correctional Complex, holding that the court of appeals correctly dismissed Appellant's petition for failure to state a claim upon which relief in habeas corpus could be granted.Appellant pled no contest to gross sexual imposition, pandering sexually-oriented material involving a minor, and illegal use of a minor in nudity-oriented material. Appellant later filed a petition for a writ of habeas corpus, alleging that the trial court lacked jurisdiction to try him. The court of appeals dismissed the petition for failure to state a claim. The Supreme Court affirmed, holding that Appellant was not entitled to relief on his propositions of law. View "State ex rel. Martre v. Watson" on Justia Law
Posted in:
Criminal Law
Bell v. McConahay
The Supreme Court affirmed the judgment of the court of appeals denying Michael Bell's petition seeking a writ of habeas against the warden of the Mansfield Correctional Institution (MCI) and denied Bell's motion to reverse and vacate the judgment against him, holding that Bell was not entitled to relief.Bell, an inmate at MCI, filed a petition for a writ of habeas corpus against MCI's warden, presenting several arguments to support his claim for relief. The court of appeals granted the warden's motion to dismiss for failure to state a valid claim for relief in habeas corpus. The Supreme Court affirmed, holding that Bell could not establish that he was entitled to habeas relief under any of the theories he presented. View "Bell v. McConahay" on Justia Law
Posted in:
Criminal Law
State ex rel. Lindsay v. Dep’t of Rehabilitation & Correction
The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that Appellant was not entitled to relief on his propositions of law.Appellant was convicted of rape of a minor and other crimes. Appellant later brought this petition for a writ of habeas corpus alleging that after serving his mandatory minimum sentence he satisfied the conditions for parole and had been granted release and that he had a right to immediate release. The court of appeals denied the petition. The Supreme Court affirmed, holding that the error of the Ohio Department of Rehabilitation and Correction misinforming Appellant about his parole status did not create a constitutional right to parole. View "State ex rel. Lindsay v. Dep't of Rehabilitation & Correction" on Justia Law
Posted in:
Criminal Law
State ex rel. Boler v. McCarthy
The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of prohibition and mandamus seeking vacated of his criminal convictions, holding that Appellant had an adequate remedy in the ordinary course of the law.In 2009, Appellant was convicted of aggravated robbery and complicity to commit murder and sentenced to an aggregate term of twenty-eight years to life in prison. In 2022, Appellant filed his complaint for writs of prohibition and mandamus, arguing that the trial court lacked jurisdiction to "misapply" Ohio's aggravated robbery statute, Ohio Rev. Code 2911.01, requiring vacatur of his conviction. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law. View "State ex rel. Boler v. McCarthy" on Justia Law
Posted in:
Criminal Law