Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court affirmed the decision of the court of appeals upholding that decision of the trial court to deny Defendant's motion to suppress evidence discovered after a traffic stop, holding that there was no error.After executing the traffic stop at issue, a law enforcement officer ordered Defendant to step out of the car and opened the door for him to do so. Another officer later looked through the open door and spotted a marijuana cigarette on the floor. A subsequent search of the car led to the discovery of a pistol. Defendant pleaded no contest to firearm-related charges. On appeal, Defendant challenged the denial of his motion to suppress. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) the officers did not violate the Fourth Amendment by ordering Defendant to exit the car; (2) opening the door was not a search; (3) the second officer did not conduct a search; and (4) under the automobile exception to the warrant requirement, the discovery of the marijuana cigarette in plain view allowed the officers to search the car. View "State v. Jackson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court dismissing rape charges against Defendant due to prejudicial preindictment delay, holding that Defendant failed to demonstrate actual prejudice. In 2017, Defendant was indicted on a multiple-count indictment alleging that Defendant had raped the complaining witness in 2005. The trial court dismissed the charges. The court of appeals affirmed, concluding that Defendant had demonstrated actual prejudice. The Supreme Court affirmed reversed after clarifying that, in determining whether unconstitutional preindictment delay has occurred in a rape case in which consent is at issue, the relevant inquiry is whether the defendant has shown actual prejudice, holding that Defendant failed to show actual prejudice under the standard set forth in State v. Jones, 69 N.E.3d 688 (Ohio 2016). View "State v. Bourn" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the the trial court's decision ordering $1,615 in restitution for lost wages of the victim after Defendant pleaded guilty to two fifth-degree felony charges, holding that unless the loss of wages is directly and proximately caused by the offense, lost wages are not compensable as restitution.During the restitution hearing the victim testified that she was seeking restitution for lost wages relating to the wages she lost as a result of attending hearings for the criminal cases. The trial court ultimately ordered restitution for the lost wages of the victim. The court of appeals reversed. The Supreme Court affirmed, holding that the statutory meaning of restitution was not altered or expanded by Ohio Const. art. I, 10a, otherwise known as Marsy's Law, and that crime victims should receive restitution from those whose crimes that have directly and proximately caused them to suffer economic loss or detriment. View "State v. Yerkey" on Justia Law