Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions and sentence for three counts of aggravated murder, six counts of aggravated robbery and other crimes and his sentence of life in prison, holding that a trial court errs in its evaluation of a defendant's lack of remorse when it considers that defendant's decision to waive allocution and remain silent at sentencing if the defendant exercised his right to a jury trial.Specifically, the Supreme Court held (1) the lower courts did not err in determining that Defendant did not waive his attorney-client privilege with regard to direct communications with his attorney; (2) even if this case presented circumstances in which the attorney-client privilege yielded to Defendant's right to confrontation, any error was not prejudicial; and (3) while the trial court erred in considering Defendant's decision to waive allocution and remain silent in determining whether he lacked remorse, the error was not prejudicial. View "State v. Brunson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court denying Appellant's petition for postconviction DNA testing, holding that the postconviction DNA testing sought by Appellant was outcome determinative as required by Ohio Rev. Code 2953.74(C)(4) and (5).Appellant was convicted of murder, assault, and rape and sentenced to fifteen years to life. Appellant later filed a petition for postconviction DNA testing. The trial court denied the application, concluding that it did not satisfy the "outcome determinative" standard set forth in Ohio Rev. Code 2953.74(D). The Supreme Court reversed, holding that the lower courts abused their discretion by unreasonably concluding that there was not a strong probability that a reasonable fact-finder would have found Defendant guilty if a DNA test result excluding Defendant had been presented at trial. View "State v. Scott" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the juvenile court to transfer Appellant to adult court, holding that that court's decision to transfer Appellant to adult court was not supported by a preponderance of the evidence and that the juvenile court abused its discretion by relinquishing jurisdiction.After the juvenile court transferred jurisdiction over Appellant to the general division a jury found Appellant guilty of aggravated murder and murder for a killing that occurred when he was fourteen years old. The court of appeals affirmed the conviction, concluding that the juvenile court did not violate Appellant's constitutional right to due process by transferring his case to the adult court. The Supreme Court reversed, holding (1) the standard of proof applicable to discretionary-bindover proceedings is a preponderance of the evidence, and the state need not produce affirmative evidence of nonamenability; (2) a juvenile court need not consider all potential juvenile dispositions when balancing the factors weighing in favor of and against transfer; and (3) the juvenile court improperly relinquished jurisdiction in this case. View "State v. Nicholas" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding Defendant's conviction of felony murder for a one-punch homicide, holding that Defendant failed to establish that his trial counsel provided ineffective assistance.Defendant killed an eighty-three-year-old man by punching him in the face, causing the victim to crash to the ground and strike his head on the concrete. After a jury trial, Defendant was found guilty of felony murder and felonious assault. On appeal, Defendant argued that his trial counsel was ineffective for failing to request jury instructions on lesser-included and inferior-degree offenses. The Supreme Court disagreed and affirmed, holding that Defendant failed to demonstrate that his counsel misunderstood the law or that he would have been entitled to additional jury instructions had his attorney requested them. View "State v. Lloyd" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated murder and his sentence of death, holding that, while error occurred in this case in the form of repetitive crime scene photos, the prosecutor's misstatements, and sentencing opinion errors, none of the errors resulted in prejudicial error.After a jury trial, Defendant was found guilty of the aggravated murders of his four-year-old daughter, C.D., and her mother, Nicole Duckson, with accompanying death-penalty specifications. The court sentenced Defendant according to the jury's recommendation of a sentence of death for the aggravated murder of C.D. The court then sentenced Defendant to life without parole for the aggravated murder of Nicole. The Supreme Court affirmed but remanded the case, holding (1) Defendant received a fair trial, and none of the errors in this case, when considered either individually or cumulatively, resulted in prejudicial error; (2) the overwhelming evidence established Defendant's guilt; and (3) the case must be remanded for the trial court to issue a nunc pro tunc entering confirming the September 14, 2019 judgment entry and the September 16, 2019 entry to the sentence that was imposed at the sentencing hearing. View "State v. Garrett" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions, entered upon his guilty plea, for involuntary manslaughter, having weapons while under a disability, and aggravated riot, holding that the juvenile court's probable cause determination was not subject to a manifest-weight challenge on appeal.The State filed a complaint in the juvenile court alleging that Defendant committed involuntary manslaughter and related offenses. The juvenile court determined that the State had established probable cause to believe that Defendant committed the offense and transferred Defendant's case to the general division. Defendant ultimately pled guilty. On appeal, Defendant argued that the juvenile court erred in transferring his case to the general division. The court of appeals affirmed. The Supreme Court affirmed, holding that a juvenile court's probable cause determination at a mandatory binder hearing is not subject to a manifest-weight review on appeal. View "State v. Martin" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that a person adjudicated a juvenile delinquent may not reopen his or her direct appeal from the adjudication based on a claim of ineffective assistance of appellate counsel under App.R. 26(B).The juvenile division of the court of common pleas adjudicated T.A. a delinquent child. The Ninth District Court of Appeals affirmed. T.A. subsequently filed an application to reopen his direct appeal under App.R. 26(B). The Ninth District denied the application, concluding that a child adjudicated delinquent may not apply for reopening of his or her appeal from the adjudication under the rule. The Supreme Court affirmed, holding that App.R. 26(B) does not apply to juvenile adjudications. View "In re T.A." on Justia Law