Justia Ohio Supreme Court Opinion Summaries

The Supreme Court held that a three-year prison term imposed under Ohio Rev. Code 2950.99(A)(2)(b) is to be imposed "in addition to" any prison term imposed under "any other provision of law," including a sentence imposed under Ohio Rev. Code 2929.14(A)(3)(b).In 2013, Defendant was convicted of unlawful sexual conduct with a minor. In 2018, Defendant was convicted of failing to provide a change of address notification for his sex offender registration, in violation of Ohio Rev. Code 2950.05(F)(1), and sentenced to serve three years and nine months in prison. On appeal, Defendant argued that section 2929.14(A)(3)(b) limited his possible sentence for a thirty-degree felony to a maximum of thirty-six months. The court of appeal affirmed Defendant's sentence. The Supreme Court affirmed, holding that, under the unambiguous language of section 2950.99(A)(2)(b), a trial court must impose a three-year prison sentence "in addition to" the sanctions imposes under section 2929.14. View "State v. Ashcraft" on Justia Law

The Supreme Court held that Defendant's sentence constituted cruel and unusual punishment under the Eighth and Fourteenth Amendments to the United States Constitution and Ohio Const. art. I, 9 when he was convicted as a juvenile and the trial court failed to consider his youth as a mitigating factor in sentencing.Defendant was charged with allegedly committing acts which, if committed by an adult, would constitute the offense of complicity to aggravated murder and other crimes. After a jury trial, Defendant was found guilty of several charges, and the trial court sentenced him to an indefinite life sentence in prison with parole eligible after thirty-eight to forty-three years. The Supreme Court reversed, holding that the trial court's sentence was unconstitutional because the court failed to consider Defendant's youth as a factor in sentencing. View "State v. Morris" on Justia Law

The Supreme Court held that Ohio Rev. Code 2929.14(C)(4) requires trial courts to consider the overall number of consecutive sentences and the aggregate sentence to be imposed when making the necessity and proportionality findings required for the imposition of consecutive sentences and that appellate review of consecutive sentences under Ohio Rev. Code 2953.08(G)(2) does not require deference to the trial court's findings under section 2929.14(C)(4).At issue was whether Defendant's sixty-five-year aggregate sentence for numerous nonviolent felonies violated section 2929.14(C)(4), Ohio's consecutive sentencing statute, or the Eighth Amendment to the United States Constitution. The Supreme Court reversed the court of appeals' judgment affirming Defendant's sixty-five year sentence and remanded the case for further consideration in light of the Court's clarification on how sections 2929.14(C)(4) and 2953.08(G)(2) are to be applied, holding (1) consecutive sentence findings must be made in consideration of the aggregate term to be imposed; and (2) appellate review of consecutive sentences does not require appellate courts to defer to the sentencing court's findings. View "State v. Gwynne" on Justia Law

The Supreme Court reversed the portion of the judgment of the court of appeals affirming Appellant's conviction on count twenty-nine of the indictment and vacated that conviction and affirmed the portion of the judgment affirming Defendant's convictions on counts eleven, twenty, forty-five, forty-six, and fifty-five of the indictment, holding that, based on State v. Smith, 194 N.E.3d 197 (Ohio 2022), the adult court lacked subject matter jurisdiction over count twenty-nine.In Smith, the Supreme Court held that a finding of probable cause is a jurisdictional prerequisite under Ohio Rev. Code 215.212 to transferring a child to adult court for prosecution. In the instant case, Appellant argued that the adult court lacked subject-matter jurisdiction over count twenty-nine of the indictment because the juvenile court did not find probable cause to believe that Appellant had committed the act charged in that count. The Supreme Court agreed and reversed the court of appeals' decision affirming Appellant's conviction on count twenty-nine and otherwise affirmed, holding that Appellant's remaining claims of error were without merit. View "State v. Burns" on Justia Law

The Supreme Court reversed the opinion of the the court of appeals affirming the trial court's denial of Defendant's motion to suppress evidence recovered as a result of a constitutionally-defective search warrant, holding that the good-faith exception to the exclusionary rule did not apply to the search of cell phones in this case.At issue was a constitutionally-deficient search warrant authorizing the search of cell phones found at the scene of a car crash. Nothing in the affidavit connected the cell phones to the accident except a police officer's averment that evidence of how the accident occurred may be found on the phones. The court of appeals affirmed the denial of Defendant's motion to suppress for lack of probable cause, upholding the cell-phone search under the good faith exception to the exclusionary rule. The Supreme Court reversed, holding (1) the warrant was constitutionally defective for want of probable cause in the warrant's supporting affidavit; and (2) the good-faith exception to the exclusionary rule did not apply. View "State v. Schubert" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals ruling that the state's rebuttal of a defendant's claim of self-defense is not subject to review under the sufficiency-of-the-evidence standard, holding that the state's new burden of disproving the defendant's self-defense claim beyond a reasonable doubt is subject to a manifest-weight review on appeal.After a jury trial, Defendant was convicted of murder and felony murder and sentenced to eighteen years to life in prison. On appeal, Defendant argued that the state had not presented legally sufficient evidence to establish that he had not acted in self-defense and that the state had failed to disprove self-defense under a "manifest weight" standard. The court of appeals rejected Defendant's claims and affirmed. The Supreme Court affirmed, holding (1) the 2018 Am.Sub.H.B. No. 228 amendments to Ohio Rev. Code 2901.05 did not eliminate Defendant's burden of production regarding a claim of self-defense; (2) the state's new burden of disproving a self-defense claim beyond a reasonable doubt is subject to a manifest-weight review on appeal; and (3) the court of appeals did not err in declining to review the state's rebuttal of self-defense for sufficiency of the evidence. View "State v. Messenger" on Justia Law

The Supreme Court reversed the judgment of the court of appeals finding that the trial court did not abuse its discretion by denying Defendant's request to enter a plea of no contest on the ground that the court did not believe there were any legitimate issues to raise on appeal, holding that the trial court abused its discretion.Defendant was indicted on five drug-related counts. Defendant informed the court that he wished to proceed with a no-contest plea, but the trial court denied Defendant's request on the ground that there was no legitimate issue for appeal. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court abused its discretion by denying Defendant's request to enter a no-contest plea based on its own review of the appealable issues. View "State v. Hill" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court denying Defendant's motion to withdraw his guilty plea, holding that Defendant had a reasonable and legitimate basis to withdraw his guilty plea.Pursuant to a plea deal from the state, Defendant pleaded guilty to involuntary manslaughter. Defendant subsequently filed a motion to withdraw his guilty plea, asserting that his attorneys did not review all the discovery with him. The trial court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) a defendant has a reasonable and legitimate basis to withdraw his guilty plea when, before sentencing, he discovers evidence that his attorney withheld from him and that would have negated his decision to plead guilty had he known about it; and (2) the trial court erred by not granting Defendant's motion to withdraw his guilty plea. View "State v. Barnes" on Justia Law

The Supreme Court held that if an offender who is on community control is convicted and imprisoned for a new offense, the revocation proceeding in the original case may not result in a prison sentence that runs consecutively to the new prison sentence if no mention was made of consecutive sentences as part of the original sentence for community control.Defendant pled guilty in Harrison County to endangering children. The trial court sentenced her to five years of community control with a two-year prison sentence reserved. Later, the trial court revoked Defendant's community control based on Defendant's conviction for robbery in a Jefferson County case, for which she had received a term of three years' imprisonment. The trial court ordered Defendant to serve the reserved two-year sentence consecutively to the three-year sentence imposed in the Jefferson County case. The court of appeals vacated the sentence. The Supreme Court affirmed, holding that the trial court was not authorized to impose a consecutive prison term on Defendant because she was not advised that if she violated the terms of her community control, she might be ordered to serve the two-year reserved prison term consecutively to any other sentences. View "State v. Jones" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for three abduction charges, holding that the State erred in failing to provide Defendant with a bill of particulars in this case.Defendant was indicted for the abduction of his grandchildren who lives and stayed with him after his unmarried daughter died. Defendant requested a bill of particulars to understand how his actions constituted the offense of abduction. The State, however, refused to provide one, and twice the trial court refused to compel the State to provide one. The Supreme Court vacated Defendant's conviction, holding that the State fell short of what is required under the Constitution by not giving Defendant notice of exactly what it was alleging he did that could have constituted the offenses charged. View "State v. Haynes" on Justia Law