Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction and sentence for one count each of aggravated murder, aggravated burglary, aggravated robbery, and attempted rape, holding that the trial court did not erred in denying Defendant's motion to suppress his socks and underwear, but the error was harmless.After the murder in this case, Defendant was taken to the hospital and examined. Defendant filed a motion to suppress the evidence obtained from his hospital room, including the hospital's washcloth, scrapings taken from his fingernails, and his socks and underwear. The trial court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the trial court did not err in denying Defendant's motion to suppress the washcloth and fingernail scrapings; and (2) the trial court erred in denying Defendant's motion to suppress his socks and underwear, but the error was harmless. View "State v. LaRosa" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus, holding that Appellant failed to show that he was entitled to the writ.In 1993, Appellant pleaded guilty to aggravated murder with a capital specification and was sentenced to life with parole eligibility after thirty years. In 2020, Appellant filed his petition for a writ of habeas corpus, alleging that his sentence was not a permissible sentence under Ohio law. The court of appeals dismissed the complaint, concluding that Appellant's sentence was voidable, not void, and therefore, Appellant did not state a claim for relief in habeas corpus. The Supreme Court affirmed, holding that the court of appeals did not err in dismissing the complaint. View "State ex rel. Slaughter v. Foley" on Justia Law

The Supreme Court held that neither a showing of exigent circumstances nor a showing of the impracticability of obtaining an arrest warrant is necessary to sustain the constitutionality of a warrantless arrest under either the Ohio Constitution or the United States Constitution.Defendant was convicted of multiple drug offenses. On appeal, Defendant challenged the trial court's denial of his motion to suppress, arguing that his arrest was unlawful because there were no exigent circumstances to justify a warrantless arrest. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a warrantless arrest based on probable cause and conducted in public is reasonable under the Fourth Amendment; (2) neither exigent circumstances nor the impracticability of obtaining a warrant is required to justify a warrantless felony arrest that is supported by probable cause and that is conducted in public; and (3) the arrest in this case was constitutionally valid. View "State v. Jordan" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus and his motions for discovery and for oral argument, holding that there was no error.Appellant, who was serving a fifty-five-year prison sentence, filed a petition for a writ of habeas corpus. The court of appeals dismissed the petition without reaching the merits of Appellant's claims for habeas relief. The Supreme Court affirmed, holding (1) the court of appeals correctly dismissed Appellant's habeas petition; and (2) because Appellant's affidavit of indigency was deficient under Ohio Rev. Code 2969.25(C) the court of appeals did not err in dismissing the petition. View "Robinson v. State" on Justia Law

The Supreme Court affirmed Appellant's petition for a writ of habeas corpus against Appellee, the warden of the correctional institution at which Appellant was an inmate, holding that there was no error.In his habeas petition, Appellant argued that he was entitled to the writ because he was no properly bound over from juvenile court to adult court for prosecution for offenses that he committed while he was a juvenile. The court of appeals granted summary judgment in favor of Appellee on Appellant's petition. The Supreme Court affirmed, holding that Appellant failed to show that there was a genuine issue of material fact on his claim for habeas corpus relief. View "Humphrey v. Bracy" 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 Appellee, the former warden of the correctional institution at which Appellant was an inmate, holding that there was no error.Appellant was convicted of four counts of complicity to commit rape and was sentenced to four consecutive terms of life imprisonment. Many years later, Appellant filed against the warden a complaint for a writ of habeas corpus alleging that he was not informed of his right to appeal. The court of appeals dismissed the action. The Supreme Court affirmed, holding that the court of appeals correctly dismissed Appellant's complaint for a writ of habeas corpus. View "Dunkle v. Hill" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that the Retroactivity Clause of the Ohio Constitution prohibits the state from applying "Sierah's Law," Ohio Rev. Code 2903.41 through 2903.44, to an offender whose criminal conduct occurred prior to the legislation's effective date, holding that this Court's determination in State v. Hubbard, __ N.E.3d __ (Ohio 2021), was dispositive of this case.Sierah's Law, which created a violent offender database, became effective March 20, 2019. Appellant in this case pleaded guilty on March 4, 2019 to several crimes. At a sentencing hearing on April 1, 2019, Appellant was notified of his duty to register as a violent offender. The court of appeals reversed, concluding that the Retroactivity Clause prohibited the state from applying Sierah's Law to Appellant. The Supreme Court reversed, holding that, adhering to this Court's determination in Hubbard, the application of Sierah's Law to conduct that occurred prior to its effective date does not violate the Retroactivity Clause of Ohio Const. art. II, 28. View "State v. Jarvis" on Justia Law

The Supreme Court held that the application of "Sierah's Law," Ohio Rev. Code 2903.41 through 2903.44, to conduct that occurred prior to its effective date, does not violate the Retroactivity Clause of Ohio Const. art. II, 28.Seirah's Law presumptively requires offenders who are convicted of certain crimes to enroll in Ohio's "Violent Offender Database" for a period of ten years and presumptively requires an offender to enroll if he was convicted of any of those offenses or was serving a termination of confinement for the offense on or after the provisions' effective date. The court of appeals in this case determined that Sierah's Law does not affect a substantive right because it does not "impose a new burden in the constitutional sense" and therefore may be applied to conduct that occurred prior to its effective date. The Supreme Court affirmed, holding that the application of Sierah's Law to violent offenders who committed their offenses prior to its effective date does not violate the Retroactivity Clause of the Ohio Constitution. View "State v. Hubbard" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition requesting a writ of mandamus to compel the Cuyahoga County Court of Common Pleas to vacate journal entries that modified Appellant's original sentencing entries in two criminal cases, holding that the court of appeals did not err.In 1978, Appellant was convicted, in two separate cases, of numerous crimes. In 2021, Appellant filed a petition for a writ of mandamus alleging that the common pleas court patently and unambiguously lacked jurisdiction to modify his sentences while his convictions were being challenged on appeal. Specifically, Appellant alleged that after he had filed his notices of appeals of his convictions the common pleas court filed journal entires stating that his sentencing entries were modified in part. The court of appeals dismissed the petition and found Appellant to be a vexatious litigator. The Supreme Court affirmed, holding that the court of appeals (1) correctly dismissed Appellant's petition because he did not allege facts showing that the relief he sought would benefit him; and (2) did not err in finding Appellant to be a vexatious litigator. View "State ex rel. Newell v. Cuyahoga County Court of Common Pleas" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court dismissing Plaintiffs' complaint seeking an injunction halting their execution and a declaration that the Department of Rehabilitation and Correction's (DRC) written execution protocol was invalid, holding that there was no error.Plaintiffs were two condemned inmates who challenged the DRC's written execution protocol setting forth the specific process by which DRC personnel are to carry out death sentences by lethal injection. Specifically, Plaintiffs argued (1) DRC may adopt the execution protocol only by following the procedures for promulgating it as an administrative rule, in accordance with Ohio Rev. Code 111.15(B); and (2) until these procedures were followed, the protocol was invalid and could not be used to carry out death sentences. The trial court granted summary judgment for the State, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the execution protocol was neither a rule having a general and uniform application nor an internal management rule; and (2) therefore, the protocol was not subject to the rule-making requirements of Ohio Rev. Code 111.15. View "O'Neal v. State" on Justia Law