Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals upholding Defendant's conviction of involuntary manslaughter, holding that Defendant's argument on appeal was without merit.Defendant committed a felony when he fired his gun at the scene of a fatal shooting because he was under disability as a result of a prior, unrelated drug offense that prohibited him from having or using a firearm. On appeal, Defendant argued that his prior drug offense that formed the basis for his firearms disability was unrelated to the victim's death, and therefore, his involuntary manslaughter conviction was improper. The Supreme Court affirmed, holding that, by its plain terms, Ohio Rev. Code 2903.04(A) simply requires that a person cause the death of another "as a proximate result" of the commission of a felony. View "State v. Crawford" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing Defendant's convictions after finding that the state failed to prove venue, holding that the court of appeals did not err.Defendant was indicted in Erie County for retaliation, attempted aggravated murder, and conspiracy arising from conversations that he had with his cellmate while he was incarcerated in Marion County. Defendant objected to venue and requested that the proceedings be transferred to Marion County, but the motion was summarily denied. A jury then found Defendant guilty of all three charges. The court of appeals reversed, concluding that venue was improper in Erie County. The Supreme Court affirmed, holding that the State failed to prove that venue was proper in Erie County. View "State v. Moore" on Justia Law

The Supreme Court held that the general division of a common pleas court does not have jurisdiction over an offender who was arrested at the age of twenty for felonious acts he allegedly committed as a juvenile.Appellant was arrested at the age of twenty for acts he allegedly committed when he was seventeen years old, acts that would have been felonious had they been committed by an adult. Appellant was first indicted in the general division of the court of common pleas. The State recognized that the general division did not have jurisdiction over Appellant under Ohio Rev. Code 2152.02(C)(3) and 2151.23(I) and moved to dismiss the indictment. The indictment was dismissed, but because Appellant was twenty-two years old at that point, the State reindicted him in the general division the next day. The court of appeals affirmed. The Supreme Court reversed, holding that the jurisdiction of the general division of the court of common pleas is not invoked when a person is arrested at the age of twenty for felonious acts that he allegedly committed as a juvenile. View "State v. Hudson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the trial court finding Robert Burns strictly liable as a public official for the misappropriation of public money, holding that Burns was not strictly liable for the embezzled funds.Burns contracted with New City Community School, a charter school, to be its chief executive officer, and Carl Shye was an independent contractor hired by New City to be the school's treasurer. After the auditor of state concluded that more than $50,000 of New City's state and federal grants had been misappropriated the Attorney General filed a complaint against Burns, Shye, and other defendants, alleging that they were jointly and severally liable as public officials. The trial court found Burns strictly liable. The Supreme Court reversed, holding that Burns was not strictly liable for the embezzled funds because he did not receive or collect the public money that was misappropriated. View "State ex rel. Yost v. Burns" on Justia Law

The Supreme Court affirmed the court of appeals' decision affirming the judgment of the trial court dismissing the criminal case against Defendant without prejudice, holding that the trial court did not err when it denied the State's requests to issue a material-witness warrant.The court of appeals concluded that the trial court properly denied the State's requests to issue the material-witness warrants because the State failed to demonstrate probable cause that warrants were necessary to procure the witnesses' attendance at trial. The Supreme Court affirmed, holding (1) when the State requests that a court issue a material-witness warrant it must establish, by either oath or affidavit, probable cause to believe that the witness is material and that the warrant is necessary to procure the witness's attendance at trial; and (2) the trial court did not err in this case. View "State v. Eatmon" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court denying Appellant's motion for leave to file a motion for a new trial and his motion for a new trial and finding that it lacked jurisdiction to consider Appellant's successive postconviction petition, holding that there was no error in the proceedings below.Appellant was convicted of two counts of aggravated murder and sentenced to death. Appellant later filed a motion for leave to file a motion for a new trial, claiming that the prosecution violated Brady v. Maryland, 373 U.S. 83 (1963). In a second filing, Appellant both submitted a successive petition for postconviction relief and moved for a new trial. The trial court denied all relief. The Supreme Court affirmed, holding (1) the trial court correctly dismissed Appellant's successive postconviction petition for lack of subject matter jurisdiction; and (2) Appellant's failure to meet his burden under Ohio Rev. Code 2953.23(A)(1)(b) required denial of Appellant's motion for leave to file a motion for a new trial. View "State v. Bethel" on Justia Law

The Supreme Court affirmed the judgment of the Eleventh District Court of Appeals dismissing Appellant's declaratory judgment and habeas claims but transferring his mandamus claim to the Tenth District Court of Appeals, holding that there was no error.Appellant, an inmate, filed an original action asserting that the revocation of his parole violated his rights to due process, free speech, and equal protection. Appellant sought a declaratory judgment of wrongful imprisonment, a writ of habeas corpus ordering his release from prison, and a writ of mandamus ordering the warden and the chair of the parole board to comply with established controlling law. The Eleventh District dismissed all but the mandamus claim then transferred the action to the Tenth District. The Supreme Court affirmed, holding that Appellant's potential remedy lay in mandamus. View "State ex rel. Guthrie v. Fender" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court denying Petitioner's request for injunctive and declaratory relief claiming that the application of Ohio Rev. Code 2969.271 to his conduct violated his rights under the First and Fourteenth Amendments to the United States Constitution, holding that the lower courts erred.Section 2969.271 allows the Ohio Department of Rehabilitation (DRC) and Correction to administratively extend an incarcerated defendant's prison term beyond his minimum prison term or presumptive earned early-release date but not beyond his maximum prison term. Petitioner entered Alford pleas to attempted burglary and other offenses. The trial court imposed a sentence under the "Reagan Tokes Law." On appeal, Petitioner argued that the sections of the statute allowing DRC to extend his prison term beyond the presumptive minimum term was unconstitutional. The court of appeals concluded that Petitioner's constitutional challenge was not ripe for review. The Supreme Court reversed, holding that a criminal defendant's challenge to the constitutionality of section 2969.271 is ripe for review on the defendant's direct appeal of his conviction and prison sentence. View "State v. Maddox" 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 the City of Beachwood to terminate special prosecutor Stephanie Scalise, holding that this case was moot.Burkons was charged with one count of interfering with civil rights. City Prosecutor Nathalie Supler moved for leave to withdraw as counsel due to a conflict of interest because Burkons was a city council member. Supler asked the trial court to appoint Scalise as special prosecutor in this case. The municipal court judge granted the motion. Burkons eventually filed a complaint in mandamus against the City challenging Scalise's "unauthorized representation of the City." The court of appeals dismissed the mandamus action. The days earlier, a writ of prohibition was issued halting the criminal case against Burkons based on improper venue. The Supreme Court affirmed the dismissal of Appellant's mandamus complaint, holding that this action was moot. View "State ex rel. Burkons v. Beachwood" on Justia Law

The Supreme Court denied requests sought by four Summit County Municipal Court judges for writs of prohibition and mandamus against Respondents, the Summit County Court of Common Pleas and its administrative judge, holding that that Plaintiffs failed to establish that they were entitled to the writs.The office of the county executive asked the municipal court judges at issue to stop appointing counsel for indigent unindicted felony defendants, concluding that municipal court appointments of private counsel were a misuse of public funds when representation was already provided for in contracts with the Legal Defender Office. Plaintiffs filed a complaint for writs of mandamus and prohibition to prevent the appointment of counsel by the common pleas court judges while a case is pending in the municipal court. The Supreme Court denied the writ, holding that municipal court judges have not established that common pleas court judges are in fact making such appointments appointments and that nothing in the local rules clearly states that common pleas court judges may do so. View "State ex rel. McKenney v. Jones" on Justia Law