Justia Ohio Supreme Court Opinion Summaries

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

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