Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that Appellant's petition was moot.Appellant pleaded no contest to several drug-related offenses and was sentenced to six years' imprisonment. Appellant later filed a petition for writ of habeas corpus, arguing that sentencing errors entitled him to immediate release. The court of appeals granted the warden's motion to dismiss under Civ.R. 12(B)(6) for failure to state a valid claim in relief. After he appealed, Appellant was released from prison. The Supreme Court affirmed the court of appeals' dismissal of the action, holding that Appellant's release from incarceration meant that his habeas claim was moot. View "State ex rel. Johnson v. Foley" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against the Ohio Department of Rehabilitation and Correction (DRC), holding that the court of appeals correctly dismissed the petition for failure to state a claim upon which relief can be granted.Appellant was convicted of aggravated robbery with a firearm specification and sentenced to an aggregate prison term of ten years. Appellant later filed a petition for a writ of mandamus, arguing that he had completed his maximum sentence. The court of appeals dismissed the petition, seeing no need to correct DRC's sentence calculation. The Supreme Court affirmed, holding that the DRC correctly calculated what Appellant's aggregate sentence should be. View "State ex rel. Scott v. Ohio Dep't of Rehabilitation & Correction" on Justia Law

The Supreme Court reversed the judgment of the court of appeals determining that the evidence should have been suppressed in the underlying criminal case based on a statutory violation, holding that there was no violation of Defendant's Fourth Amendment rights in this case.While Defendant was serving community control, his probation officer conducted a random home-check on Defendant, searched his cell phone, and discovered child pornography. Defendant moved to suppress the uncovered evidence on the grounds that the suspicion-less search violated the Fourth Amendment. The district court denied the suppression motion. The court of appeals reversed, concluding that the search violated Ohio Rev Code 2951.02(A)'s requirement that a probation officer may conduct a search only when there are "reasonable grounds to believe" that a probationer is violating the law or conditions of control. The Supreme Court reversed, holding (1) the probation officer exceeded the scope of her authority when she searched Defendant's cell phone without reasonable grounds to believe that he had violated the law or the conditions of probation; and (2) because there was no constitutional violation, there was no basis to exclude the evidence obtained as a result of the search. View "State v. Campbell" on Justia Law

The Supreme Court held that Defendant was properly sentenced for murder and that the failure of a sentencing entry to track precisely the language of the applicable criminal sentencing statutes does not render the sentence contrary to law.Defendant was convicted of murder and sentenced to "life in prison with eligibility [for] parole after 15 years." The sentencing entry, however, did not precisely track the language of the applicable criminal sentencing statute. The court of appeals vacated Defendant's murder sentence, concluding that the trial court's sentencing language regarding the murder count was dissimilar enough from the language of Ohio Rev. Code 2929.02(B)(1) to require vacation of that sentence and a remand for resentencing. The Supreme Court reversed in part, holding (1) whatever difference existed between the language of section 2929.02(B)(1) and the language in Defendant's sentencing entry, the difference was de minimis; and (2) Defendant's murder sentence complied with section 2929.02(B)(1). View "State v. Leegrand" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's mandamus complaint under Civ.R. 12(B)(6) for failure to state a claim upon which mandamus relief can be granted, holding that the court of appeals did not err or abuse its discretion.Appellant, an inmate, commenced this mandamus action alleging that the parole board erred in determining the date of his first eligibility for parole. DRC filed a motion to dismiss the complaint for failure to state a claim. The court of appeals granted the motion after noting that the crux of Appellant's argument was that his second parole hearing should take place four years earlier than currently scheduled because his initial parole hearing was four years too late. The Supreme Court affirmed, holding that the court of appeals correctly dismissed Appellant's complaint for failure to state a valid claim for mandamus relief. View "State ex rel. Shine v. Ohio Dep't of Rehabilitation & Correction" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court dismissing the indictment in this case with prejudice, holding that the trial court properly dismissed the indictment but erred when it dismissed the indictment with prejudice.At issue was what constitutes adequate notice to inform a wholesale distributor that it is charged with drug trafficking under Ohio's drug-trafficking laws. The State charged Appellants, who were in the business of wholesale distribution, with drug trafficking for acting "not in accordance with Chapter 4729 of the Ohio Revised Code." The trial court granted Appellants' motion to dismiss on the grounds that the State failed to provide them with sufficient notice. The court of appeals reversed. The Supreme Court reversed, holding (1) in a drug-trafficking case against a wholesale distributor, the State must prove that the wholesale distributor failed to act in accordance with Chapter 4729; and (2) the State failed to identify the nature and cause of the accusation against Appellants, and therefore, the case must be dismissed without prejudice. View "State v. Troisi" on Justia Law

The Supreme Court granted a writ of mandamus ordering the Mahoning County Board of Elections to place Eric Ungaro's name on the November 2022 general election ballot as an independent candidate for the office of state representative, holding that Ungaro successfully established that he was entitled to the writ.Ungaro filed a statement of candidacy and nominating petition to run as an independent candidate for the office of state representative of the 59th Ohio House District in the November 2022 general election. The Board rejected the petition by a vote of three to one. Ungaro then filed this action seeking a writ of mandamus ordering the Board to place his name on the ballot. The Supreme Court affirmed, holding that the Board abused its discretion by invalidating Ungaro's petition in an arbitrary fashion. View "State ex rel. Ungaro v. Mahoning County Bd. of Elections" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's mandamus complaint for failure to satisfy the affidavit requirement of Ohio Rev. Code 2969.25(A), holding that Appellant failed to demonstrate any error in the court of appeals' judgment of dismissal.In 1993, Appellant was convicted of murder. In 2021, Appellant commenced this action seeking a writ of mandamus ordering the Ohio Adult Parole Authority to remove all incorrect information from his file and order a new parole hearing. The court of appeals dismissed the action after finding that Appellant's affidavit of prior actions was fatally deficient. The Supreme Court affirmed, holding that the court of appeals correctly dismissed this action for failure to comply with section 2969.25(A). View "State ex rel. Pointer v. Ohio Adult Parole Authority" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus sought by Appellant to compel Judge Julie M. Lynch to vacate certain nunc pro tunc entries, holding that Appellant was not entitled to the writ.Appellant was sentenced in 2003 on more than sixty felony counts involving crimes he committed in four separate cases. This appeal involved three cases that included offenses Appellant committed after postrelease control became part of Ohio's sentencing scheme in 1996. Prior to Appellant's release from prison in 2020, Judge Lynch issued the nunc pro tunc entries at issue, which corrected some of Appellant's sentencing entries to include references to the imposition of a mandatory five-year term of postrelease control. Appellant brought this action seeking a writ of mandamus to compel Judge Lynch to vacate the entries. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant did not have a clear legal right to relief in mandamus. View "State ex rel. Randlett v. Lynch" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the order of the trial court ordering forfeiture of Appellant's 2014 Chevrolet Silverado, holding that there was no equal protection violation and that, as applied to Appellant, the vehicle forfeiture did not violate the Excessive Fines Clause of the Eighth Amendment.Appellant entered a plea of no contest to one charge of operating a vehicle while intoxicated (OVI). Because Appellant had two prior OVI convictions within the preceding ten years, his vehicle was seized pending the completion of the proceedings. After a forfeiture hearing held pursuant to Ohio Rev. Code 4503.234 the trial court ordered Appellant to forfeit his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the statutory classification contained in Ohio Rev. Code 4511.19(G)(1)(c)(v) does not violate constitutional equal protection guarantees; and (2) the forfeiture of Appellant's vehicle was not grossly disproportional and was thus not unconstitutional as applied to Appellant. View "State v. O'Malley" on Justia Law