Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the court of appeals dismissing the original action filed by Appellant seeking a writ of mandamus to compel the trial court to permit Appellant to independently test a certain evidence sample taken from the crime scene, holding that there was no error.In this action arose out of a capital murder case pending before the county court of common pleas the trial court granted the State's motion to permit DNA testing of an evidence sample that would consume the entire sample. Appellant, the defendant in the case, filed an original action seeking a writ of mandamus to compel the trial court to permit Appellant to independently test the sample. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that Appellant failed to comply with Ohio Rev. Code 2969.25(C). View "State ex rel. Swopes v. McCormick" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's sentences in connection with his conviction for robbery, kidnapping, abduction and rape, holding that the plain error doctrine was not properly applied by the court of appeals.Defendant was convicted following a jury trial. For purposes of sentencing, the trial court merged the abduction and kidnapping counts but concluded that the kidnapping and rape counts did not merge. Defendant did not object at sentencing to the trial court's failure to merge the kidnapping and rape counts. The court of appeals reversed, concluding that the trial court committed plain error by failing to merge the kidnapping and rape counts, which were allied offenses of similar import. View "State v. Bailey" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that the trial court committed harmless error by not holding a competency hearing after one was requested by Defendant's counsel prior to trial, holding that the trial court's error was not harmless.In affirming Defendant's conviction, the appellate court rejected Defendant's argument that a new trial was warranted because of the trial court's failure to conduct a hearing on Defendant's motion for a competency evaluation. Specifically, the appellate court held that the error was harmless because "the record lacks sufficient indicia of incompetency." The Supreme Court reversed and vacated Defendant's convictions, holding that the trial court erred to Defendant's prejudice by not conducting a hearing on his motion for competency evaluation. View "State v. Hough" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction and sentence for felonious assault, holding that the court of appeals erred in determining that the State lacked standing to appeal the trial court's restitution under Ohio Const. art. I, 10a, also known as Marsy's Law.After a jury trial, Defendant was convicted of one count of felonious assault in violation of Ohio Rev. Code 2903.11(A)(1) and one count of felonious assault in violation of Ohio Rev. Code 2903.11(A)(2). The trial court sentenced Defendant to an indefinite term of imprisonment of two to three years and denied the victim's request for restitution to compensate him for the medical bills he incurred as a result of the assault. Defendant appealed and the State cross-appealed, challenging the trial court's decision to deny restitution. The court of appeals affirmed, ruling that the State lacked standing to appeal the restitution order under Marsy's Law. The Supreme Court reversed and remanded the matter for the court of appeals to consider the merits of the State's cross-appeal, holding that the scope of Marsy's Law was inadequate to answer whether the State was entitled to appeal the denial of restitution to the victim. View "State v. Fisk" on Justia Law

The Supreme Court held that an offender must receive separate prison terms for multiple firearm specifications when the criminal offenses to which those firearm specifications were attached had been merged as allied offenses.Appellant pleaded guilty to involuntary manslaughter, felonious assault, and having weapons while under a disability. The trial court merged the involuntary-manslaughter and felonious-assault counts but imposed a three-year prison term for each of the firearm specifications linked to those counts. The court of appeals affirmed. The Supreme Court affirmed, holding that the plain language of Ohio Rev. Code 2929.14(B)(1)(g) requires that offenders like Appellant receive separate prison terms for convictions on multiple firearm specifications. View "State v. Bollar" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that Ohio Rev. Code 2953.08(D)(3) was not unconstitutional for precluding appellate review of a sentence for aggravated murder and reversed the portion of the judgment declining to review Appellant's challenges to his aggravated-murder sentence based on Ohio Rev. Code 2953.08(D)(3), holding that remand was required.At issue was section 2953.08(D)(3), which states that a "sentence imposed for aggravated murder or murder pursuant to sections 2929.02 to 2929.06 of the Revised Code is not subject to review under this section." In State v. Patrick, 172 N.E.3d 952 (Ohio 2020), the Supreme Court held that section 2953.08(D)(3) does not preclude an appellate court from reviewing an offender's sentence for aggravated murder when the offender raises a constitutional claim regarding that sentence on appeal. Patrick was decided after the court of appeals affirmed Defendant's sentence. The Supreme Court reversed in part, holding (1) the court of appeals properly upheld the constitutionality of section 2953.08(D)(3); and (2) in light of State v. Patrick, 172 N.E.3d 952 (Ohio 2020), the case must be remanded for the court of appeals to consider the merits of Appellant's constitutional challenges to his aggravated-murder sentence. View "State v. Grevious" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court to deny Appellant's petition for postconviction relief, holding that, under the circumstances of this case, the court abused its discretion in denying Appellant's petition for postconviction relief.In 2016, Appellant was found guilty of aggravated murder, gross abuse of a corpse, and tampering with evidence. The trial court sentenced Appellant to life in prison without the possibility of parole for the aggravated murder. Appellant later filed a petition for postconviction relief arguing that her trial counsel provided ineffective assistance in failing to present evidence about neonaticide, as it is currently understood, as a mitigating factor. The trial court denied the petition, and the court of appeals affirmed. The Supreme Court reversed, holding that the trial court's decision denying Appellant's postconviction petition was unreasonable and arbitrary and not based on competent and credible evidence. View "State v. Weaver" on Justia Law