Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the court of appeals dismissing his complaint for a writ of mandamus against Former Hamilton County Common Pleas Court Judge Robert C. Winkler and denying his motion for summary judgment, holding that there was no error.Appellant was convicted of aggravated robbery and other offenses and sentenced to consecutive sentences. After the trial court issued a nunc pro tunc sentencing entry including the findings necessary to impose consecutive sentences Appellant filed a complaint for a writ of mandamus alleging that Judge Winkler lacked jurisdiction to change his sentence. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that Appellant's complaint failed to state a claim in mandamus because he did not name any respondent who could grant the relief he sought. View "State ex rel. Adams v. Winkler" on Justia Law

The Supreme Court denied Petitioner's petition seeking a writ of mandamus ordering his release from prison or, alternatively, an order requiring the Ohio Adult Parole Authority (APA) to impose a shorter prison term, holding that Petitioner failed to show that he was entitled to the writ.A hearing officer found that Petitioner committed four postrelease-control violations and imposed a prison term of 235 days. Petitioner later commenced this action seeking a writ of mandamus ordering his release because the APA had not charged him within ten business days of his arrest, as required by a Ohio Department of Rehabilitation and Correction policy. The Supreme Court denied the writ and the motions filed in connection with the writ request, holding that Petitioner was not entitled to any of the relief he sought. View "State ex rel. Shie v. Ohio Adult Parole Authority" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Appellant's conviction and vacated the conviction, holding that no adult court had jurisdiction over acts that were charged in but not bound over by the juvenile court.Appellant was sixteen years old when he was charged with committing the category-two offense of aggravated robbery while possessing a deadly weapon. Binding Appellant over to adult court would have been mandatory for counts one and two upon a finding of probable cause. The juvenile court found probable cause as to counts one through three and count five, a misdemeanor. After the case was transferred to the adult court, Appellant pled guilty to several charges. On appeal, Appellant argued that the adult court lacked jurisdiction to consider the charges for which the juvenile court found no probable cause. The Supreme Court reversed, holding that in the absence of a juvenile court's finding probable cause or making a finding that the juvenile is unalienable to care or rehabilitation within the juvenile system, no adult court has jurisdiction over acts that were charged in but not bound over by the juvenile court. View "State v. Smith" on Justia Law