Justia Ohio Supreme Court Opinion Summaries

The case concerns an individual who pleaded guilty in 2004 to two counts of forgery, both fifth-degree felonies, after depositing counterfeit checks and withdrawing funds from a credit union. The trial court sentenced him to concurrent nine-month prison terms and ordered him to pay $2,663 in restitution to the victim, Mid-State Credit Union, and $408 in court costs. The sentencing entry specified that these amounts were entered as civil judgments. After serving his sentence and completing postrelease control, the individual applied in 2022 to have the record of his convictions sealed, though he had not paid the restitution.The Franklin County Court of Common Pleas granted the application to seal the records, despite the State’s objection that restitution remained unpaid. The State appealed, but the Tenth District Court of Appeals affirmed the trial court’s decision. The appellate court reasoned that because the restitution was entered “as a civil judgment,” it was not a criminal sanction that needed to be satisfied before the record could be sealed. The court further concluded that the civil judgment for restitution had become permanently dormant under debtor-protection laws, as it had not been revived within the statutory period.The Supreme Court of Ohio reviewed the case and held that, regardless of how a restitution order is labeled in a sentencing entry, it remains a criminal sanction that is part of the sentence. Therefore, restitution must be paid before an offender is eligible to apply to have the record of conviction sealed. The court reversed the judgment of the Tenth District Court of Appeals and remanded the case for consideration of the individual’s constitutional arguments. View "State v. T.W.C." on Justia Law

In 1996, the defendant pleaded guilty to several first-degree felonies, including rape, attempted aggravated murder, kidnapping, and aggravated burglary, for acts committed in 1995. The trial court imposed an aggregate indefinite prison sentence of 15 to 50 years under the sentencing laws in effect before July 1, 1996. Over the years, the defendant challenged aspects of his sentence and conviction, including the indefinite nature of his sentence and the lack of eligibility for judicial release, but these challenges were unsuccessful.After serving more than 26 years, the defendant filed a motion for judicial release under R.C. 2929.20 in December 2021, arguing that he was serving a “stated prison term” and had completed the mandatory portion of his sentence. The State of Ohio opposed the motion, asserting that the defendant was serving an indefinite sentence under pre-S.B. 2 law and was therefore ineligible for judicial release. The trial court granted the motion for judicial release, placing the defendant on community control, and the State appealed. The Seventh District Court of Appeals affirmed, reasoning that amendments to R.C. 2929.20 had expanded eligibility for judicial release to include offenders serving nonmandatory sentences on or after April 7, 2009.The Supreme Court of Ohio reviewed the case and held that the definition of “eligible offender” for purposes of judicial release under R.C. 2929.20 includes only those serving a “stated prison term,” as defined in R.C. 2929.01. The court concluded that an offender serving an indefinite sentence imposed under pre-S.B. 2 law does not meet this definition and is therefore not eligible for judicial release. The Supreme Court of Ohio reversed the judgment of the Seventh District Court of Appeals and remanded the case to the trial court to deny judicial release. View "State v. Staffrey" on Justia Law

A resident of Lucas County, along with his nephews, was involved in a drug-selling enterprise known as the Tecumseh Street Gang, which operated primarily on the 800 block of Tecumseh Street in Toledo. The group was a subset of a larger gang, the Southside Gangster Disciples. Law enforcement, using a confidential informant, discovered that a woman named Armijo was distributing cocaine for the Tecumseh Street Gang. On several occasions, Armijo purchased cocaine from one of the nephews in Lucas County and then traveled to Henry County to resell the drugs. She often bought the drugs on credit, keeping a portion of the profits after paying the supplier.The defendant was charged in the Henry County Court of Common Pleas with engaging in a pattern of corrupt activity. At trial, he argued that venue was improper in Henry County because Armijo was not part of the same enterprise. The trial court denied his motion for acquittal, and the jury found him guilty, also finding that venue was proper. On appeal, the Third District Court of Appeals upheld the conviction, concluding that the evidence supported the finding that Armijo was associated with the same enterprise and that her activities in Henry County established proper venue.The Supreme Court of Ohio reviewed the case to determine whether venue in Henry County was appropriate for prosecuting the defendant under R.C. 2923.32. The court held that venue was proper in any county where a member of the enterprise conducted activity on behalf of the enterprise, even if the defendant himself did not act there. The court found sufficient evidence that Armijo was associated with the enterprise and that her drug sales in Henry County were part of its activities. The Supreme Court of Ohio affirmed the judgment of the Third District Court of Appeals. View "State v. Brown" on Justia Law

A man who had attended elementary school with a woman, but had never been friends or even acquaintances with her, began contacting her more than a decade later. The woman, A.P., posted on her public Instagram account for her 29th birthday, and the man, Dorian Crawl, commented with a “sad emoji” and a message expressing affection and a desire to meet. A.P. did not respond. Days later, Crawl commented again on another post, asking if the video showed her house. Less than a month after these online interactions, Crawl appeared uninvited at A.P.’s apartment, knocked on her door, identified himself as her “friend,” and turned the doorknob. A.P., frightened, locked the door, hid her daughter, and called the police. Crawl later admitted to police that he had found A.P.’s address online and continued to message her even after being confronted by law enforcement. A.P. testified that these events caused her significant anxiety and changes to her daily life.The Miamisburg Municipal Court found Crawl guilty of menacing by stalking under R.C. 2903.211(A)(1). On appeal, the Second District Court of Appeals affirmed the conviction, holding that Crawl’s pattern of conduct—including the social media messages and the uninvited visit—along with A.P.’s testimony about her mental distress, was sufficient to support the conviction.The Supreme Court of Ohio reviewed the case and affirmed the judgment of the Second District Court of Appeals. The court held that, when viewing the evidence in the light most favorable to the prosecution, a rational trier of fact could find that the essential elements of menacing by stalking were proven beyond a reasonable doubt. The court clarified that explicit threats, a prior relationship, or notice from the victim are not required to establish the offense. The court concluded that Crawl’s actions constituted a pattern of conduct, caused mental distress, and were done knowingly. View "State v. Crawl" on Justia Law

A husband and wife met at a religious conference, began a relationship, and married after the wife made clear she would not have sex before marriage. After moving to Ohio, the husband began demanding sex more frequently than the wife desired, insisting she submit regardless of her wishes. The wife described a recurring pattern during their marriage in which “date nights” would end with consensual sex, followed by the husband engaging in nonconsensual vaginal intercourse or oral sex while she was asleep or otherwise unwilling. This pattern continued for several years, leading to the wife’s departure, her obtaining a protection order, and the husband’s indictment on three counts of rape, each tied to specific time periods.The case was tried before a jury in the Wood County Court of Common Pleas, which convicted the husband on all three counts. On appeal, the Sixth District Court of Appeals reversed the convictions and vacated them, finding the evidence insufficient to prove “sexual conduct” as defined by Ohio law for the charged periods. The appellate court reasoned that while the wife’s testimony about “date nights” included explicit descriptions of penetration, her testimony regarding the specific periods in the indictment did not explicitly describe penetration, and the use of phrases like “have sex” was deemed too vague to establish the statutory element.The Supreme Court of Ohio reviewed the case and held that the wife’s testimony, including her explicit descriptions of vaginal intercourse and her use of the phrase “have sex,” was sufficient to support the element of “sexual conduct” under Ohio’s rape statute when viewed in the light most favorable to the prosecution. The court concluded that the appellate court erred by refusing to draw reasonable inferences in favor of the State and reversed the judgment, remanding the case for consideration of the husband’s remaining appellate arguments. View "State v. Coker" on Justia Law

Aarin Clinkscale was indicted in 2014 for his involvement in an armed robbery that resulted in two deaths. He pled guilty to aggravated robbery with a firearm specification and two counts of involuntary manslaughter. In 2016, the trial court sentenced him to a total of 14 years in prison, including a mandatory three-year term for the firearm specification. Clinkscale received 762 days of jail-time credit for time served prior to sentencing.Clinkscale filed his first motion for judicial release in June 2020, which the trial court denied, stating he would be eligible for release in October 2022. He filed a second motion for judicial release in October 2022. The State objected, arguing that Clinkscale was not eligible until November 2024, as he needed to serve the mandatory term and then wait five years. The trial court granted Clinkscale’s motion, and the State appealed to the Tenth District Court of Appeals. The appellate court affirmed the trial court’s decision, concluding that Clinkscale’s jail-time credit shortened the waiting period for judicial release.The Supreme Court of Ohio reviewed the case and disagreed with the Tenth District’s conclusion. The court held that jail-time credit does not reduce the required five-year waiting period following the expiration of mandatory prison terms under R.C. 2929.20(C)(1)(d). The court emphasized that the five-year waiting period is fixed and begins only after the mandatory term is completed. Consequently, Clinkscale’s motion for judicial release was premature. The Supreme Court of Ohio reversed the judgment of the Tenth District Court of Appeals and remanded the case for consideration of Clinkscale’s equal-protection argument. View "State v. Clinkscale" on Justia Law

Ricardo Dodson is serving prison sentences for convictions in two separate cases. In the first case, Dodson was indicted on multiple counts of rape, attempted rape, and kidnapping. The jury returned guilty verdicts, but the jury-verdict forms mistakenly listed his surname as Jackson instead of Dodson. The trial-court judge read the wrong name into the record and sentenced Dodson to consecutive prison terms for each count. In the second case, Dodson was indicted on another count of rape and kidnapping. He was found guilty and sentenced to serve this sentence consecutively to the sentences from the first case, even though he had not yet started serving those sentences.Dodson petitioned the Seventh District Court of Appeals for a writ of habeas corpus, arguing that the mistyping of his surname on the jury-verdict forms stripped the trial court of jurisdiction and that the sentences imposed were ambiguous. He claimed that the sentence in the first case should be considered concurrent due to the lack of specificity in the sentencing entry and that the sentence in the second case was ambiguous because it referred to a sentence "already being served" when he had not yet started serving the first sentence.The Seventh District Court of Appeals dismissed Dodson’s petition, determining that his claims were not cognizable in habeas corpus. The court found that the alleged errors did not affect the trial court’s jurisdiction and that Dodson had an adequate remedy in the ordinary course of law through direct appeal. Dodson appealed to the Supreme Court of Ohio.The Supreme Court of Ohio affirmed the Seventh District’s judgment, holding that the trial court had jurisdiction over Dodson’s case and that the sentencing entries were not ambiguous. The court concluded that Dodson’s arguments could have been addressed through direct appeal and did not warrant habeas corpus relief. View "State ex rel. Dodson v. Smith" on Justia Law

Jadyn Logan was convicted of aggravated robbery in January 2018, a first-degree felony that prohibited her from possessing a firearm under R.C. 2923.13(A)(2). Later, a Cuyahoga County grand jury indicted her for having weapons while under a disability, improperly handling firearms in a motor vehicle, and carrying a concealed weapon. Logan pleaded guilty to attempting to have weapons while under a disability with a one-year firearm specification, and the other charges were dismissed. The trial court sentenced her to one year for the firearm specification and two years of community control for the attempt offense.The State appealed to the Eighth District Court of Appeals, arguing that R.C. 2929.13(F)(8) required a prison term for the attempt offense. The Eighth District affirmed the trial court's decision, holding that the statute required a prison sentence only for the firearm specification, not the underlying felony offense. The State sought en banc consideration, which was denied, and the Eighth District maintained its position.The Supreme Court of Ohio reviewed the case and determined that R.C. 2929.13(F)(8) mandates a prison sentence for any felony offense with a corresponding firearm specification. The court clarified that a firearm specification is a sentencing enhancement, not a separate offense, and that the statute's language requires a prison term for the underlying felony offense when a firearm specification is attached. The court reversed the Eighth District's judgment and remanded the case to the trial court for resentencing consistent with this interpretation. View "State v. Logan" on Justia Law

James P. Ellis, an inmate at Marion Correctional Institution, has been incarcerated since his 1995 convictions for aggravated burglary and aggravated murder. He contends that the Ohio Adult Parole Authority unlawfully corrected an error in his sentencing entry and has been using this correction in his parole hearings. Ellis sought a writ of prohibition from the Tenth District Court of Appeals to prevent the parole authority from conducting future parole screenings and to compel it to contact the sentencing court for corrective procedures.The Tenth District Court of Appeals dismissed Ellis's complaint. The court reasoned that Ellis did not sufficiently demonstrate that the parole authority lacked jurisdiction or relied on erroneous information. Additionally, the court noted that compelling the parole authority to contact a court is beyond the scope of relief provided by a writ of prohibition.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District's dismissal. The court held that the parole authority has jurisdiction to hold parole proceedings for all parole-eligible inmates, including Ellis. The court found that Ellis's parole eligibility is determined by statute, and the parole authority's actions were authorized by law. Consequently, Ellis failed to prove the elements required for a writ of prohibition. The court also noted that Ellis's request to compel the parole authority to contact the sentencing court was not appropriate for a writ of prohibition, which is typically used to prevent unauthorized actions rather than to compel specific actions. View "State ex rel. Ellis v. Adult Parole Auth." on Justia Law

Niquan M. Dunn was indicted on six counts in the Geauga County Common Pleas Court, including drug-related crimes and possession of criminal tools. Counts 2 and 4, relevant to this appeal, charged Dunn with aggravated trafficking in drugs and trafficking in cocaine, respectively, with enhancements for committing the crimes "in the vicinity of a juvenile." The case proceeded to trial, where the State presented evidence including testimony from detectives and a controlled buy operation. Drugs and drug paraphernalia were found in a house where Dunn was staying, and a four-month-old child was present in the home.The trial court denied Dunn's motion for acquittal on Counts 1 through 5 and the jury found him guilty on those counts. Dunn was sentenced to a total of 36 months in prison. On appeal, the Eleventh District Court of Appeals reversed the convictions in part, finding insufficient evidence that Dunn committed the crimes in the vicinity of a juvenile, as required for the enhancement. The appellate court focused on the lack of direct evidence that the child was present during the drug activities and distinguished the case from prior decisions.The Supreme Court of Ohio reviewed the case and held that the evidence was sufficient to support the "in the vicinity of a juvenile" enhancement. The court emphasized that circumstantial evidence and reasonable inferences drawn from the evidence could lead a reasonable juror to conclude that the child was present when Dunn prepared the drugs for distribution. The court reversed the Eleventh District's judgment, reinstating the enhancement on Count 2. View "State v. Dunn" on Justia Law