Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to dismiss two of the charges against him, holding that toxicology results trigger a new speedy-trial period for charges premised on the commission of a per se operating a vehicle while under the influence of alcohol or drugs (OVI) offense.The State charged Defendant with one felony offense related to a car accident in which Defendant killed another driver and was held in jail pending indictment. The grand jury's indictment, however, included additional charges based on toxicology results that had not been available at the time of Defendant's arrest. At issue was whether the charges based on Defendant's drug-test results were subject to the same speedy-trial period as the original charge. The Supreme Court held (1) the test results were new information necessary to establish that Defendant operated a vehicle with a prohibited level of drugs in his system; and (2) therefore, the State was entitled to a new speedy-trial period for the charges premised on the per se OVI offense. View "State v. Sanford" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that dismissed counts in an indictment may be sealed before the conviction is eligible to be sealed, holding that the court of appeals erred.Defendant was indicted on multiple counts and plead guilty to one count. The State dismissed the remaining counts as part of a plea deal. Before he was eligible to have the record of his conviction sealed Defendant filed an application to seal, asserting that the trial court could seal the portions of the record pertaining to the dismissed charges pursuant to Ohio Rev. Code 2953.52. The trial court denied the application to seal. The court of appeals reversed. The Supreme Court reversed, holding that under the plain language of the statutes governing sealing, the dismissed counts in the indictment may not be sealed until the conviction is eligible to be sealed. View "State v. G.K." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus against the Ohio Department of Rehabilitation and Correction, Annette Chambers-Smith, the Ohio Adult Parole Authority, and the Ohio Bureau of Sentencing Computation (collectively, DRC), holding that there was no error.Appellant, an inmate, filed an original action in the court of appeal seeking a writ of mandamus to compel DRC to correct what he alleged were inaccurate records pertaining to him and alleging that he had a right to be released from custody under Ohio Rev. Code 2967.15(B). The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant failed to show error, let alone plain error, in the judgment of the court of appeals. View "State ex rel. Anderson v. Chambers-Smith" on Justia Law

The Supreme Court vacated Defendant's conviction for aggravated burglary, vacated the finding of guilt on count three charging Defendant with felony murder during an aggravated battery, and dismissed the death penalty specifications predicated on aggravated burglary but affirmed Defendant's remaining convictions and his death sentence, holding that there was insufficient evidence to convict Defendant of burglary.After a trial, a jury found Defendant guilty of aggravated murder and three accompanying death-penalty specifications. The trial court sentenced Defendant to death. The Supreme Court largely affirmed, holding (1) contrary to Defendant's argument on appeal, the indictment in this case was not defective; (2) there was insufficient evidence to convict Defendant of aggravated burglary; (3) no plain error occurred during the prosecutor's trial-phase closing argument; and (4) there were constitutional violations in this case. View "State v. Whitaker" on Justia Law

The Supreme Court held that a trial court lacks discretion to deny a request for a recommended change in the commitment conditions of a mentally ill person subject to court-ordered commitment to a mental health facility when the state has failed to present clear and convincing evidence that the change represents a threat to public safety or any person.Appellant was found not guilty by reason of insanity of murder, tampering with evidence, and abuse of a corpse. The trial court ordered Appellant committed to a mental health facility. The chief clinical officer at the facility later filed a request with the trial court asking that Appellant be allowed to leave the facility to go on trips (Level IV community movement). The trial court denied the request, and the appellate court affirmed. The Supreme Court reversed, holding that the appellate court erred in concluding that the trial court had discretion to deny the requested change in Appellant's commitment level even if the state failed to meet its burden of proof. View "State v. Stutler" 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 Warden Ed Sheldon of the Allen-Oakwood Correctional Institution, holding that the court of appeals properly dismissed the petition.Appellant, an inmate, filed a petition for a writ of habeas corpus alleging that he had served his entire prison sentence. The court of appeals dismissed the habeas corpus petition for failure to comply with Ohio Rev. Code 2725.04(D), which requires a habeas petition to contain a copy of the commitment or cause of detention. The Supreme Court affirmed, holding that where Appellant failed to attach all sentencing records to his habeas corpus petition, the court of appeals properly dismissed the petition. View "State ex rel. Davis v. Sheldon" on Justia Law

The Supreme Court vacated the judgment of the court of appeals determining that Appellant's appeal of the denial of his motion to modify the terms of his intervention-in-lieu-of-conviction (ILC) supervision was moot and declining to address the merits, holding that the court erred.Appellant was charged with aggravated possession of drugs and requested ILC under Ohio Rev. Code 2951.041. The trial court granted the request. Appellant later moved to modify the terms of his ILC supervision. The trial court denied the motion. The court of appeals dismissed the appeal as moot. The Supreme Court vacated the judgment below, holding that the order denying the modification of the conditions of ILC was not a final appealable order. View "State v. Yontz" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's decision to overrule Defendant's motion for leave to move for a new trial, holding that the trial court abused its discretion in denying Defendant's motion for leave to move for a new trial.After a jury trial, Defendant was found guilty of rape and sentenced to eleven years in prison. The court of appeals affirmed. Defendant subsequently filed a motion for leave to move for a new trial, asserting that certain undisclosed evidence was exculpatory. The trial court overruled the motion. The court of appeals affirmed, concluding that Defendant's motion for leave was untimely. The Supreme Court reversed, holding that Defendant's motion for leave to move for a new trial should be granted because he was unavoidably prevented from timely moving for a new trial within the time specified in Crim.R. 33(B) due to the state's suppression of evidence. View "State v. McNeal" on Justia Law

The Supreme Court denied a petition for a writ of habeas corpus against Respondent, warden at the Grafton Correctional Institution (GCI), sought by Petitioner, an inmate at GCI, holding that Petitioner was not entitled to the writ.Petitioner pleaded guilty to one count of gross sexual imposition and was sentenced to a prison term of two to five years and placed on probation. He later pled guilty to rape and felonious assault. Eight years later, Petitioner pleaded guilty to attempted rape. In his petition, Petitioner alleged that he had served his maximum prison sentence. The Supreme Court denied relief, holding that Petitioner's sentence will not expire until at least 2026, and therefore, Petitioner was not entitled to a writ of habeas corpus. View "Jones v. Foley" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated murder and his sentences of death on each count but reversed the trial court's judgment imposing postrelease control on counts three, four, and five, holding that Defendant's convictions and sentences should be affirmed.Specifically, the Supreme Court held (1) the trial court erred in imposing postrelease control for counts that had been merged for sentencing; (2) no other error, individual or cumulative, occurred in the underlying proceedings; and (3) under an independent review of Defendant's death sentences, the evidence supported the findings regarding the aggravated and mitigating circumstances, and the death sentences were proportionate. View "State v. Brinkman" on Justia Law