Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus to compel Portage County Common Pleas Court Judge Laurie J. Pittman to vacate his convictions for burglary and gross sexual imposition, holding that the court of appeals correctly dismissed Appellant's mandamus complaint.In his mandamus complaint, Appellant argued that he was entitled to relief because the trial court lacked subject-matter jurisdiction to accept his guilty pleas and to sentence him for the offenses for which he was convicted. The court of appeals dismissed the complaint for failure to state a claim. The Supreme Court affirmed, holding that Appellant did not allege a valid claim in mandamus. View "State ex rel. Mitchell v. Pittman" on Justia Law

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 claims were not cognizable in habeas corpus.In 1996, Appellant was convicted of aggravated murder and other crimes and sentenced to a life term in prison. In 2021, Appellant filed a petition for a writ of habeas corpus demanding his release from prison on the grounds that the trial court lacked the authority to impose a life term of imprisonment under the circumstances and that certain counts should have been merged for sentencing. The court of appeals dismissed the action, concluding that the petition failed to state a valid claim for relief in habeas corpus. The Supreme Court affirmed, holding that Appellant's claims were not cognizable in habeas corpus. View "Stevens v. Hill" on Justia Law

The Supreme Court held that 2018 Am.Sub.H.B. 228, which shifted the burden of proof on self-defense to the prosecution, applies to all trials conducted on or after its effective date of March 28, 2019, irrespective of when the underlying alleged criminal conduct occurred.On September 20, 2018, Appellant was indicted for aggravated burglary and other crimes. After a jury trial, Appellant was convicted. On appeal, Appellant argued that she was deprived of a fair trial when the trial court required her to bear the burden of proving that she had acted in self defense. The court of appeals affirmed, holding that the trial court had properly instructed the jury because the burden-shifting changes to Ohio Rev. Code 2901.05 did not apply retroactively. The Supreme Court reversed, holding that H.B. 228 must be applied to all pending and new trials that occur on or after its effective date of March 28, 2019. View "State v. Brooks" 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 Marion Correctional Institution, holding that there was no error or abuse of discretion.Appellant was convicted of four counts of aggravated murder and sentenced to two consecutive terms of life in prison without the possibility of parole for the murders. Appellant later filed a petition for a writ of habeas corpus alleging errors in the grand jury process that led to his indictment. The court of appeals dismissed the petition. The Supreme Court affirmed and denied Appellant's motion for an order compelling the Mahoning County Clerk of Courts to submit the complete record of his underlying criminal case for consideration on appeal, holding that the court of appeals properly dismissed Appellant's petition for failure to state a claim upon which relief could be granted. View "State ex rel. Barnette v. Hill" on Justia Law

The Supreme Court reversed the judgment of the trial court finding Defendant guilty of kidnapping and rape and a repeat-violent-offender specification and imposing a ten-year sentence on each count, to be served concurrently, holding that the trial court denied Defendant his constitutional right to a fair jury as guaranteed by the Sixth and Fourteenth Amendments to the United States Constitution.At issue was whether Defendant's right to a fair trial was violated when the alleged victim was introduced to the jury as the State's designated representative and was permitted to sit at counsel table with the prosecutor during the proceedings. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court erred in designating the alleged victim as the State's representative and by allowing her to sit at the prosecutor's table and that the error was not harmless, requiring reversal. View "State v. Montgomery" on Justia Law

The Supreme Court denied relief in this original action brought by Relator, an inmate at the Toledo Correctional Institution (TCI), brought seeking a writ of mandamus to fulfill his public records request he previously made to the records custodian for TCI (Respondent), holding that Relator was not entitled to the writ.In her affidavit, Respondent denied that TCI had any records requested by Relator. Respondent then brought this mandamus action. The Supreme Court denied the writ, holding that Relator requested information other than records, and therefore, he was not entitled to a writ or to his requested statutory damages. View "State ex rel. Griffin v. Sehlmeyer" on Justia Law

The Supreme Court determined that a warrantless search conducted in this case did not comport with the Fourth Amendment under the "single-purpose-container exception" to the warrant requirement, holding that when police search a bookbag in a home under circumstances that do not give rise to any exigency they must first obtain a warrant.After he was charged with illegal possession of drugs Defendant filed a motion to suppress, arguing that the warrantless search of the book bag conducted by a law enforcement officer was unlawful. The trial court denied the motion, concluding that the warrantless search was lawful because the book bag was in plain view and the officer had probable cause to suspect it contained contraband. The court of appeals affirmed. The Supreme Court reversed, holding (1) absent exigent circumstances, the search of a closed container requires a warrant; and (2) the single-purpose-container exception to the warrant did not apply in this case because a bookbag is not a single-purpose drug container. View "State v. Burroughs" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's action seeking a writ of mandamus ordering the trial court to hold a new sentencing hearing, holding that the court of appeals correctly dismissed the mandamus petition.Appellant was convicted of child endangering and felony murder. The trial court merged the offenses and determined that the sentences should run concurrently. Appellant later moved to vacate the "void sentences." The court of appeals concluded that the judgment of conviction was void because only one sentence could be imposed for the merged offenses. On remand, the trial court modified the sentence. Appellant subsequently brought this mandamus action asking the court of appeals to order the trial court to vacate its previous judgment and hold a new sentencing hearing. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant's appeal of the modified sentencing order constituted an adequate remedy in the ordinary course of law. View "State ex rel. Cherry v. Bryant" on Justia Law

The Supreme Court reversed the judgment of the court of appeals upholding Defendant's sentence, holding that a defendant's display of disrespect toward a trial court is not a permissible sentencing factor that the court may consider under Ohio Rev. Code 2929.11 and 2929.12.The trial court in this case increased Defendant's prison sentence by six years in response to Defendant's misbehavior while reacting to the length of a previously-imposed prison sentence. The court of appeals affirmed. The Supreme Court reversed, holding (1) a defendant's outburst or other courtroom misbehavior may not result in an increased sentence for the underlying crime; and (2) the six-year increase in Defendant's sentence was contrary to law. View "State v. Bryant" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus against the current prison warden for failing to state a claim upon which relief could be granted, holding that there was no error.Appellant pleaded guilty to several crimes, including two counts of gross sexual imposition and one count of rape. Appellant later filed a petition for a writ of habeas corpus, claiming that the trial court lacked jurisdiction to accept his plea and sentence him because his competency had been called into question. The court of appeals granted the warden's motion to dismiss. The Supreme Court affirmed, holding that habeas corpus will not lie in this case. View "Rance v. Watson" on Justia Law