Justia Ohio Supreme Court Opinion Summaries

In this second public-records action filed by Relators, Hogan Lovells U.S., LLP and Elizabeth Och, against Respondent, the Ohio Department of Rehabilitation and Correction (DRC), the Supreme Court denied Relators' request for a writ of mandamus requesting DRC's records relating to lethal injections, holding that Relators were not entitled to a writ of mandamus.In the first public-records case filed by Relators, the Supreme Court granted Relators' request for a writ of mandamus in part and ordered DRC to provide certain records relating to DRC's supply of drugs for its use in lethal injections. Although DRC provided more than 120 pages of documents, it asserted that two other documents at issue in this case were exempt from disclosure. Relators then brought this action seeking the withheld documents. The Supreme Court denied relief, holding that Relators were not entitled to a writ of mandamus concerning the requests but that, because DRC failed to timely respond to the request, Relators were entitled to an award of statutory damages in the amount of $500. View "State ex rel. Hogan Lovells U.S., LLP v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court held that Defendant, who pleaded no contest in 1987 to attempted murder after shooting a young man in the neck and was reindicted in 2016 for the aggravated murder of the same man after he died allegedly as a result of injuries from the shooting, may be prosecuted on the new murder charge.In 1987, Defendant pled no contest to attempted murder after shooting Danuell Jackson in the neck, leaving him paralyzed from the waist down. In 2014, Jackson died. The autospy examiner ruled the death a homicide because it was caused by infections attributed to Jackson's paraplegia. In 2016, the State indicted Defendant for the aggravated murder of Jackson. Defendant moved to dismiss the indictment, arguing that it violated the terms of a negotiated plea agreement Defendant claimed he entered into with the State in 1987. The State countered that there had not been a negotiated plea. The trial court granted Defendant's motion to dismiss. The court of appeals affirmed. The Supreme Court reversed, holding that because there was no evidence that Defendant's 1987 plea was the product of negotiations between the State and Defendant, the rule announced in State v. Carpenter, 623 N.E.2d 66 (Ohio 1993), did not prevent the State from prosecuting Defendant on the new murder charge. View "State v. Azeen" 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 officials to transfer him from the Northeast Ohio Correctional Center (NEOCC) to the Franklin County jail, holding that the court of appeals did not err.The court of appeals dismissed Appellant's complaint in its entirety as moot, concluding that any transfer of Appellant from NEOCC to the Franklin County jail would have been a vain act. The Supreme Court affirmed, holding that granting the writ of mandamus Appellant sought to compel his transfer would do nothing more than require a vain act. View "State ex rel. Peoples v. O'Shaughnessy" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus compelling Summit County Common Pleas Court Judge Alison McCarty to vacate his conviction and resentence him, holding that the court of appeals correctly dismissed Appellant's complaint.Appellant was convicted of multiple felony charges, including rape, felonious assault, and kidnapping. With respect to the kidnapping charge, the jury did not specify whether Appellant had violated Ohio Rev. Code 2905.01(A)(3), (A)(4), or both. Appellant subsequently filed a complaint for writ of mandamus alleging, among other things, that the jury failed to render a unanimous verdict. The court of appeals dismissed the complaint for failure to state a claim. The Supreme Court affirmed, holding that Appellant had an adequate remedy to challenge the alleged error in his direct appeal. View "State ex rel. Person v. McCarty" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against Lake County Common Pleas Court Judge Vincent A. Culotta, holding that the mandamus complaint was properly dismissed.Appellant was convicted of conspiracy to commit aggravated murder and other felonies. After he was sentenced, Appellant filed a motion to correct his award of jail-time credit. Unhappy with the award, the judge awarded upon granting the motion, Appellant unsuccessfully appealed. Appellant then brought a mandamus complaint seeking to compel Judge Culotta to conduct a new sentencing hearing and to correct his jail-time-credit award. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that the complaint did not state a cognizable mandamus claim. View "State ex rel. Sands v. Culotta" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against Warden Lyneal Wainwright, holding that Appellant was not entitled to immediate release.Between 1992 and 2007 Appellant was paroled four times. In 2008, Appellant was convicted of several offenses and sentenced. In his petition for writ of habeas corpus Appellant alleged that the 2008 sentencing court did not order him to serve his firearm-specification sentences consecutively to his two prior robbery sentences and that he should have been released on December 13, 2019. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that because Appellant was not complete his lawfully imposed sentences until 2025 he was not entitled to immediate release. View "State ex rel. Hunley v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus seeking to compel the Lake County Clerk of Courts to provide him with a record related to his criminal case, holding that the court of appeals correctly dismissed the complaint for failure to comply with Ohio Rev. Code 2929.25(A).In affirming the judgment, the Supreme Court noted that it was undisputed that Appellant was an inmate and that the Clerk of Courts was a government employee. Therefore, Appellant was required to comply with section 2969.25(A). The Supreme Court held that the court of appeals was correct in finding that Appellant's affidavit failed to provide the information required by section 2969.25(A)(1). View "State ex rel. Sands v. Kelly" 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 correctly dismissed the habeas petition for failure to comply with Ohio Rev. Code 2969.25(A).Appellant pleaded guilty to four counts of trafficking in cocaine and one count or engaging in a pattern of corrupt activity. The trial court sentenced Appellant to an aggregate prison sentence of fourteen years. Appellant later filed his habeas petition alleging that his sentences were void because the trial court failed to make the findings required under Ohio Rev. Code 2929.14(C)(4) before imposing consecutive prison sentences. The Supreme Court affirmed, holding that the petition was properly dismissed. View "State ex rel. Sanchez v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of procedendo and/or mandamus seeking to compel the trial court's compliance with Civ.R. 58(B), holding that, although the court of appeals' judgment dismissing the petition was correct.Appellant, an inmate, sought the writ to compel Hamilton County Court of Common Pleas Judge Steven Martin to serve upon Appellant a judgment entry in which Appellant's motion to correct his sentencing entry was denied. The court of appeals dismissed the motion. The Supreme Court affirmed, holding that granting Appellant his requested writ of mandamus was of no benefit to him because Appellant could still timely file a notice of appeal from the judgment entry. View "State ex rel. Thomas v. Nestor" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against Lake County Prosecuting Attorney Charles Coulson, holding that Appellant was not entitled to the writ.Appellant was convicted of three counts of conspiracy to commit aggravated murder, two counts of conspiracy to commit aggravated arson, and one count of engaging in a pattern of corrupt activity. In his action for a writ of mandamus, Appellant alleged that his convictions were based on perjured testimony and that Coulson had a constitutional duty to provide him a fair trial. The court of appeals granted Coulson's motion to dismiss. The Supreme Court affirmed, holding that the court of appeals correctly dismissed the complaint for failure to state a claim upon which relief can be granted because Coulson was not under a clear legal duty to perform an action that he had no legal authority to undertake. View "State ex rel. Sands v. Coulson" on Justia Law