Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals holding that the failure to have satisfied a condition of community control prevents a defendant from receiving a final discharge even after community control has been terminated, holding that the court of appeals erred.At issue was the point at which a defendant convicted of a felony attains a "final discharge" from a sentence of nonresidential community control for purposes of becoming eligible to apply to have the felony conviction sealed. The court of appeals concluded that the conditions of a defendant's nonresidential community-control sanction constitute sentencing requirements and that a defendant must satisfy all such requirements in order to receive a final discharge. The Supreme Court reversed, holding that when a defendant's nonresidential community control is terminated the defendant receives a final discharge from the community-control sanction. View "State v. P.J.F." on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's convictions and remanding the matter for a new trial, holding that the trial court did not violate Defendant's Sixth Amendment right to a public trial by partially limiting access to the courtroom after an altercation disrupted court proceedings.Defendant was indicted on two counts of murder. During a recess on the third day of trial, some of the people attending the trial were involved in an altercation outside the courtroom, which resulted in the court limiting attendees to only immediate family members. Defendant was subsequently found guilty of murder as a result of felonious assault. The court of appeals reversed, ruling that the trial court had committed structural error by failing to provide sufficient justification for the partial closure of the courtroom. The Supreme Court reversed, holding that a public trial violation occurred in Defendant's trial but that the error did not rise to the level of a plain error that must be corrected. View "State v. Bond" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court denying Appellant's motion for leave to file a motion for a new trial and a successive petition for postconviction relief without an evidentiary hearing, holding that the lower courts abused their discretion by applying res judicata to preclude Appellant's claims.In 1997, Appellant was convicted of aggravated burglary, kidnapping, rape, felonious assault, and theft. In 2018, Appellant discovered a memorandum that led him to file a motion for leave to file a motion for a new trial and a successive petition for postconviction relief. The trial court denied relief, concluding that res judicata barred Appellant's arguments because the memo was "not really new" evidence. The court of appeals affirmed. The Supreme Court reversed, holding that res judicata did not bar Appellant's motion or his petition. View "State v. Hatton" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Appellant's petitions for postconviction relief challenging his convictions in a rape case and a jail case, holding that there was no error.After a jury trial, Appellant was convicted of rape and kidnapping. While he was being held in jail on the rape charges, Appellant and two other inmates attacked one of their cellmates. A jury found Appellant guilty of felonious assault and kidnapping for the attack. Appellant later filed petitions for postconviction relief challenging his convictions in both cases. The trial court denied relief. The Supreme Court affirmed, holding (1) postconviction claims alleging a denial of the constitutional right to effective assistance of counsel are not procedurally barred if they cannot meaningfully be reviewed without resorting to evidence outside the trial record; and (2) all of Appellant's claims were either barred by res judicata or failed to set forth a substantive claim for relief. View "State v. Blanton" on Justia Law

The Supreme Court denied Petitioner's petition for a writ of habeas corpus against the warden of the Richland Correctional Institution, holding that Petitioner failed to attach his commitment papers, as required by Ohio Rev. Code 2725.04(D).Petitioner, an inmate at the institution, was serving a sentence for aggravated murder and other felonies. In his petition for a writ of habeas corpus Petitioner argued that the failure to accord him a parole hearing as required under the original sentencing entry. In his returned, the warden argued that the writ should be denied because Petitioner did not comply with section 2725.04(D). The Supreme Court agreed and denied the writ, holding that that affidavit attached to Petitioner's habeas petition did not offer a legitimate justification for Petitioner's failure to comply with section 2725.04(D). View "McDonald v. Black" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for attempted aggravated murder, holding that the statute of limitations for attempted aggravated murder and attempted murder is six years under Ohio Rev. Code 2901.13(A)(1)(a).The attempted murder in this case occurred in 1993. The victim was also kidnapped and raped, but the case went cold until 2014. When new DNA evidence revealed Defendant as a possible perpetrator, he was indicted for attempted murder. The prosecuting attorney did not seek an indictment against him for rape and kidnapping due to the expiration of the respective statutes of limitations. Defendant moved to dismiss the indictment based on the statute of limitations, but the lower court denied the motion. The court of appeals affirmed. The Supreme Court reversed, holding that the statute of limitations for attempted aggravated murder is six years, and therefore, Defendant's prosecution was barred by the statute of limitations. View "State v. Bortree" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the trial court's denial of Defendant's motion to dismiss the criminal case against him based on an alleged violation of his statutory speedy-trial right, holding that the State did not violate Defendant's speedy-trial rights.The day before trial was set to begin, Defendant moved to dismiss the case base on an alleged violation of his statutory right to a speedy trial. The trial court denied the motion. Thereafter, Defendant entered a plea of no contest to a single felony count. The court of appeals affirmed. The Supreme Court affirmed, holding that there was no violation of Defendant's statutory speedy-trial rights in this case. View "State v. Belville" on Justia Law

The Supreme Court reversed in part the judgment of the court of appeals vacating the trial court's judgment finding Defendant guilty of various sex crimes and remanding the case for a new trial without the testimony of the state's expert witness, holding that Crim.R. 16(K) precludes an expert witness from testifying at a trial commencing fewer than twenty-one days after the disclosure of the expert's written report.On appeal, Defendant argued that the trial court erred in allowing Dr. Stuart Bassman, the state's expert witness, to testify when the state failed to provide Defendant's attorney with the expert's report until six days before trial. The court of appeals agreed and remanded the case for a new trial without Dr. Bassman's testimony. The Supreme Court reversed the portion of the court os appeals' judgment precluding Dr. Bassman's testimony but otherwise affirmed, holding that Crim.R. 16(K) precludes an expert witness from testifying only at the trial commencing fewer than twenty-one days after the required disclosure is made and does not preclude otherwise admissible expert testimony at a defendant’s retrial. View "State v. Bellamy" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against the warden of the Lake Erie Correctional Institution, holding that the court of appeals correctly dismissed the petition.Appellant, who was serving an aggregate prison term of up to fifty-six years for criminal convictions dating back to 1976, filed a petition for a writ of habeas corpus in 2021, arguing that his prison term expired in 2011 and that he was entitled to immediate release. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that where Appellant had been transferred to the Mansfield Correctional Institution in Richland County, the court of appeals correctly dismissed the petition for failure to state a claim. View "State ex rel. Robinson v. Fender" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated murder with death specifications and her sentence of death, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant raised sixteen propositions of law. The Supreme Court rejected each proposition of law, holding, among other things, that (1) there was no prejudicial error in the trial court's evidentiary rulings; (2) Defendant was not entitled to relief on his ineffective assistance of counsel claims; (3) although significant mitigating factors existed, the aggravating circumstances outweighed the mitigating factors beyond a reasonable doubt; and (4) the death sentence was appropriate and proportionate. View "State v. Drain" on Justia Law