Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against Leon Hill, warden of the Marion Correctional Institution, holding that there was no error.Appellant was convicted and sentenced for aggravated robbery and felony murder. Appellant later filed a petition for a writ of habeas corpus, alleging that his convictions were nullities and that he should be immediately released. The court of appeals dismissed the petition. The Supreme Court affirmed, holding (1) the court of appeals correctly dismissed Appellant's petition on the basis of res judicata; and (2) Appellant's second proposition of law was without merit. View "Boler v. Hill" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that the court of appeals properly dismissed the petition.Appellant was convicted on multiple counts of rape, kidnapping, and felonious assault and sentenced to an aggregate prison term of 104 to 155 years. In his habeas corpus petition, Appellant asserted that the prosecution had committed a Brady violation and that the trial court erred in denying his motion for a new trial. The court of appeals dismissed the petition on the grounds that Appellant had failed to comply with Ohio Rev. Code 2969.25(C) and that the petition failed to state a valid habeas claim. The Supreme Court affirmed, holding that the court of appeals erred in dismissing the petition for failure to comply with section 2969.25(C) but was correct to dismiss the petition for failure to state a valid habeas claim. View "Davis v. Hill" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus or procedendo, holding that Appellant was not entitled to the writ.In 1992, Appellant was convicted of aggravated murder and sentenced to life imprisonment. In 2021, Appellant filed an action for writs of prohibition and mandamus seeking to have his sentence declared void because Judge Thomas Nurre erroneously imposed costs and fines. The court of appeals granted the motion to dismiss filed by the common pleas court and clerk. The Supreme Court affirmed, holding that this case fell within the general rule that a mandamus action is not an appropriate vehicle for challenging sentencing errors. View "State ex rel. Harris v. Hamilton County Clerk of Courts" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus ordering the Cuyahoga County Clerk of Courts to produce various records relating to criminal proceedings against Parker Bey in the Cuyahoga County Court of Common Pleas, holding that Bey was not entitled to relief.Twice, the court of appeals denied Bey a writ of mandamus. After the first denial of the writ, the Supreme Court held that the court of appeals erred in applying the Ohio Rules of Superintendence as a basis for denying mandamus relief and remanded for a determination as to whether Bey was entitled to relief under the Public Records Act, Ohio Rev. Code 149.43. On remand, the court of appeals again denied the writ. The Supreme Court affirmed, holding that the court of appeals did not err in denying the writ. View "State ex rel. Bey v. Byrd" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court issuing a new sentencing entry that included a required notification as to the postrelease-control portion of Defendant's sentence, holding that holding that the trial court's new sentencing entry was improper.In 2008, Defendant was sentenced to a nine-year prison term for his convictions of kidnapping, rape, and robbery. The trial court failed to include in Defendant's sentencing entry a statement that postrelease control was mandatory. In 2018, the trial court issued a new sentencing entry that included a notification that postrelease control was mandatory and that a violation of postrelease control would subject Defendant to the consequences set forth in Ohio Rev. Code 2967.28. The court of appeals affirmed. The Supreme Court vacated the portion of the 2018 sentencing entry imposing postrelease control, holding (1) res judicata precluded the State's collateral attack on Defendant's sentence; and (2) therefore, the trial court's sentencing entry was improper and of no effect. View "State v. Bates" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that the court of appeals improperly considered an unauthenticated document.Appellant, who was in prison for aggravated murder, filed a petition for a writ of habeas corpus alleging that his convictions were void because he was seventeen years old at the time of the offenses and was not bound over from juvenile court. The court of appeals granted summary judgment in favor of Warden Richard Bowen. The Supreme Court reversed, holding that the court of appeals erred by relying on a copy of the birth certificate attached to the warden's motion for summary judgment. View "State ex rel. Bradford v. Bowen" on Justia Law

The Supreme Court denied a writ of habeas corpus ordering Petitioner's release from the Lorain Correctional Institution where Jennifer Black was the warden, holding that Petitioner was not entitled to relief in habeas corpus.Petitioner was convicted of sexual battery and gross sexual imposition. After Petitioner was released from prison the Adult Parole Authority found that Petitioner had violated the terms of his postrelease control and imposed a prison term. Petitioner commenced this action seeking his release. The Supreme Court denied the writ, holding that Petitioner's argument did not state a valid claim for relief in habeas corpus. View "Simmons v. Black" 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 Warden Emma Collins, holding that there was no error.Appellant, an inmate at the Pickaway Correctional Institution where Collins was the warden, was found guilty of murder and attempted murder. Appellant field a complaint for a writ of habeas corpus alleging that the offenses of which he was convicted were neither charged in the indictment nor lesser-included offenses of the charged crimes, and therefore, his convictions were void. The court of appeals granted Collins's motion to dismiss. The Supreme Court affirmed, holding that Appellant failed to state a basis for reversal. View "Stewart v. Collins" on Justia Law

The Supreme Court granted some, but not all, of Relator's requested relief in his petition for a writ of mandamus ordering Donna Crawford, an inspector with the Trumbull Correctional Institution's office of institutional services, to produce public records that Relator had requested, holding that Relator was entitled to some of his requested relief.Relator, an inmate, sent public-records requests to Crawford, the prison's custodial of inmate-grievance records. Crawford sent some, but not all, of the requested documents. Relator then brought this action seeking a writ of mandamus and an award of statutory damages under Ohio Rev. Code 149.43(C)(2). The Supreme Court partially granted relief and awarded Relator $1,000 in statutory damages for Crawford's failure to respond fully to one request, holding that Relator met his burden to plead and prove facts showing that he requested a public record and that Crawford did not make the record available. View "State ex rel. Ware v. Crawford" on Justia Law

The Supreme Court reversed the judgment of the court of appeals denying Appellant's application to reopen his appeal, holding that Appellant's application showed that there was a genuine issue of material fact as to whether he was deprived of the effective assistance of appellate counsel.Appellant pleaded guilty to several sex-related offenses. On appeal, the court of appeals reasoned that, due to an incomplete record, it was compelled to presume regularity in the lower-court proceedings and affirmed the trial court's judgment. Represented by new appellate counsel, Appellant timely filed an application to reopen his direct appeal, asserting that his original appellate counsel's performance was deficient. The court of appeals denied the application. The Supreme Court reversed, holding that Appellant's application to reopen his appeal showed a genuine issue of ineffective assistance of appellate counsel warranting a reopening of the appeal. View "State v. Leyh" on Justia Law