Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court remanded this case to the trial court for modification of Defendant's conviction for rape of a child under the age of thirteen in violation of Ohio Rev. Code 2907.02(A)(1)(b) and for resentencing, holding that a conviction for rape based on insertion must be supported by evidence that the defendant inserted a body part or object into another.Defendant's arose from an incident in which she directed her son to insert a sex toy into her vagina and then filmed the act. On appeal, Defendant argued that a conviction for rape based on insertion must be supported by evidence that the defendant inserted a body part or object into another. The Supreme Court agreed and reversed and remanded the case, holding (1) there was insufficient to support Defendant's conviction for rape; but (2) there was sufficient evidence to sustain a conviction for gross sexual imposition, a lesser-included offense of rape. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing two complaints for writs of mandamus to compel the Bureau of Sentence Computation (BSC) and the Ohio Adult Parole Authority (APA) to produce public records, holding that the court of appeals did not err.While he was an inmate, Appellant sent a public-records request to the BSC, which Appellant allegedly never responded to. After Appellant filed his complaint for a writ of mandamus he acknowledged receiving the requested documents but argued that he was entitled to statutory damages and court costs because the BSC did not timely produce the records. Appellant also filed a mandamus complaint challenging the APA's alleged lack of response to his public records request. The APA filed a motion to dismiss based on Appellant's alleged failure to comply with Ohio Rev. Code 2969.25(A). The court of appeals dismissed the cases for failure to comply with section 2969.25(A). The Supreme Court affirmed, holding that the court of appeals correctly dismissed both mandamus complaints. View "State ex rel. Bey v. Bureau of Sentence Computation" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting a writ of habeas corpus ordering the reduction of Petitioner's bail from $1,500,000 to $500,000, holding that the court of appeals did not err.Petitioner was indicted on two counts of murder, one count of aggravated robbery, and one count of aggravated burglary. The district court set bail of $750,000 on the murder charge and a separate bail of $750,000 on the aggravated robbery charge. Petitioner filed two motions for bail reduction, which the trial court denied. Petitioner then filed a petition for a writ of habeas corpus. The court of appeals granted the writ, concluding that Petitioner's bail amount was excessive and reducing his bail to $500,000. The Supreme Court affirmed, holding that the trial court's financial condition of bail was excessive and that the record supported the court of appeals' decision to reduce Petitioner's bail. View "DuBose v. McGuffey" on Justia Law

The Supreme Court reversed the judgment of the court of appeals denying Appellant's motion for an award of statutory damages under the Ohio Public Records Act, Ohio Rev. Code 149.43, holding that Appellant was entitled to statutory damages.Appellant, an inmate, sent a request to the Cleveland Police Forensic Laboratory (CPFL) for three categories of public records. When CPFL did not respond to his request, Appellant filed a mandamus action and sought statutory damages under section 149.43(C)(2). The court of appeals granted a writ of mandamus compelling the production of some of the requested records and denied Appellant's request for statutory damages. The Supreme Court reversed and granted Appellant's application for an award of statutory damages, holding that, given the length of time during which the CPFL failed to respond, Appellant was entitled to the maximum amount permitted under the statute. View "State ex rel. Ellis v. Cleveland Police Forensic Laboratory" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the trial court granting Defendant's motion to suppress in this criminal case, holding that the absence of a signature on an arrest warrant itself alone does not negate the warrant's validity.The warrant to arrest Defendant in this case was not signed by an authorized court officer. On appeal, Defendant argued that the unsigned arrest warrant did not comply with Crim.R. 4 and was therefore invalid. The Supreme Court held (1) the arrest warrant at issue adequately complied with the requirements of Crim.R. 4 despite the absence of a court official's signature on the warrant; and (2) Defendant's arrest pursuant to the warrant did not violate the Fourth Amendment. View "State v. Harrison" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition against Appellees - Judge Dale A. Crawford and the Hocking County Common Pleas Court - but affirmed the denial of her motion for disqualification of attorney Randall L. Lambert, holding that the court of appeals erred in part.Appellant was found guilty of assaulting a police officer. At a sentencing hearing at which Appellant appeared without counsel, Appellant refused to sign a waiver-of-counsel form. Judge Crawford conducted the sentencing hearing, at the end of which he imposed a six-month sentence in the county jail and ordered Defendant to pay a fine, restitution, and court costs. Appellant filed a complaint for writs of mandamus and prohibition alleging that Judge Crawford lacked jurisdiction to hold the sentencing hearing because she had not waived her right to counsel. The court of appeals dismissed the complaint and denied the motion to disqualify Lambert. The Supreme Court reversed in part, holding that Appellant stated a colorable claim that Judge Crawford violated her Sixth Amendment rights when he ordered her to not communicate with any lawyer and then sentenced her and that this error rendered the sentencing entry void. View "State ex rel. Ogle v. Hocking County Common Pleas Court" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting a writ of prohibition preventing the order of a court of common pleas judge restoring Appellant's firearms rights from being effective, holding that a writ of prohibition was warranted.Appellant was convicted of a crime in Ohio that prohibited him, under federal law, to possess a firearm unless Appellant had his civil rights restored under Ohio law, 18 U.S.C. 921(a)(33)(B)(ii). Appellant filed an application for relief from his federal firearms disability, and Judge Peeler, a Warren County Court of Common Pleas Judge, granted the application. Appellee, Appellant's ex-wife, sought a writ of prohibition seeking to prevent Judge Peeler's order from being effective. The court of appeals granted the writ. The Supreme Court affirmed, holding that Appellee established the necessary elements for a writ of prohibition. View "State ex rel. Suwalksi v. Peeler" on Justia Law