Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the trial court terminating Defendant's community control and sentencing him to a two-year term of incarceration, holding that the trial court lacked the authority to conduct these community-control-revocation proceedings.On June 5, 2017, Defendant's community control sentence was due to expire. On September 12, 2018, the trial court revoked Defendant's community control and ordered him to serve a two-year prison term. The court of appeals reversed, holding that the trial court did not have the authority to conduct the revocation proceedings because notice of the violations and commencement of the proceedings did not occur before the expiration of Defendant's community control term. The Supreme Court affirmed, holding that the trial court lacked the authority to revoke Defendant's community control and sentence him to a term of imprisonment because the revocation proceedings were not commenced before the expiration of Defendant's community control term. View "State v. Rue" on Justia Law

The Supreme Court affirmed Defendant's convictions of aggravated murder and other crimes but vacated his death sentence, holding that the aggravating circumstances that Defendant was found guilty of committing did not outweigh the mitigating factors present in the case beyond a reasonable doubt, and therefore a sentence of death was not appropriate.Defendant was found guilty of multiple offenses, including aggravated murder and three accompanying death-penalty specifications - committing the aggravated murder during an aggravated robbery, an aggravated burglary, and a kidnapping. The trial court sentenced Defendant to death. At issue before the Supreme Court was whether the felony-murder aggravating circumstances that were found by the jury outweighed the mitigating factors presented by the defense beyond a reasonable doubt. The Supreme Court held that they did not and therefore remanded the case to the trial court for resentencing consistent with Ohio Rev. Code 2929.06. View "State v. Graham" on Justia Law

The Supreme Court affirmed Defendant's convictions for kidnapping, rape, and murder, holding that when a criminal defendant validly exercises his right to self-representation he can no longer raise claim under the Sixth Amendment to the United States Constitution that his trial counsel - standby or otherwise - was ineffective.In his criminal trial, Defendant waived his right to counsel under the Sixth Amendment and chose to represent himself. The trial court accepted Defendant's waiver and appointed standby counsel to be available to assist Defendant. On appeal, Defendant argued that the trial court violated his Sixth Amendment rights by limiting the role of his standby counsel. The court of appeals affirmed, holding that, based on the court's understanding of the typical role of standby counsel, the trial court did not improperly limit the role of standby counsel. The Supreme Court affirmed, holding that because the trial court had the discretion not to appoint standby counsel at all, the court did not abuse its discretion by appointing standby counsel with a limited role. View "State v. Hackett" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's conviction for engaging in a pattern of corrupt activity, in violation of Ohio Rev. Code 2923.32, holding that the State presented sufficient evidence to support Defendant's conviction.Defendant and two codefendants were each found guilty of engaging in a pattern of corrupt activity, possessing cocaine, illegally manufacturing drugs, and trafficking in cocaine. Defendant appealed, arguing that insufficient evidence supported his conviction for engaging in a pattern of corrupt activity. The court of appeals agreed and reversed the conviction. The Supreme Court reversed, holding that a reasonable juror could have found beyond a reasonable doubt that Defendant participated in incidents of illegal activity that were not isolated and established a pattern of corrupt activity. View "State v. Groce" on Justia Law

In these consolidated appeals the Supreme Court reversed the judgments of the court of appeals, holding that the State presented sufficient evidence to support the convictions of Alvin Dent and William Walker (collectively, Defendants) for the felony offense of engaging in a pattern of corrupt activity under Ohio Rev. Code 2923.32.After a joint jury trial, Defendants were both found guilty of engaging in a pattern of corrupt activity, possessing cocaine, illegally manufacturing drugs, and trafficking in cocaine. The court of appeals reversed each of Defendants' convictions for engaging in a pattern of corrupt activity, holding that there was insufficient evidence to support those convictions. The Supreme Court reversed, holding that a reasonable juror could have found beyond a reasonable doubt that Defendants participated in incidents of illegal activity that were not isolated and established a pattern of corrupt activity. View "State v. Dent" on Justia Law

The Supreme Court reversed the decision of the court of appeals concluding that statements made by a medical doctor during a medical board investigation were inadmissible in a subsequent criminal prosecution of that doctor, holding that the trial court properly admitted incriminating answers given by the doctor during the investigation.Specifically, the Supreme Court held (1) a medical license is a property right, and the threatened loss of the license is a form of coercion that can compromise the defendant's Fifth Amendment privilege against self-incrimination; (2) in order for coercion to be sufficient to warrant the suppression of statements made during a medical board investigative review, the coercion must be both subjectively believed and objectively reasonable; and (3) competent, credible evidence supported the trial court's factual finding that the doctor did not objectively believe that a refusal truthfully to answer questions posed by the medical board investigator could lead to the loss of the doctor's medical license. View "State v. Gideon" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals vacating certain sexually-violent-predator specifications that had been applied to Defendant's sentence, holding that, as applied, the specifications violated the Ex Post Facto Clause of the United States Constitution.Defendant was found guilty of numerous counts of rape, kidnapping, and related crimes involving three victims, including sexually-violent-predator specifications. The court of appeals upheld the convictions on all assignments of error except those challenging Defendant's convictions on the sexually-violent-predator specifications that attached to the crimes that Defendant committed before April 29, 2005. The court vacated the convictions on those specifications as violating the Ex Post Facto Clause. The Supreme Court affirmed, holding that the application of the current version of Ohio Rev. Code 2971.01(H)(1) to Defendant for his crimes in 2003 and 2005 violated the Ex Post Facto Clause. View "State v. Townsend" on Justia Law

The Supreme Court granted in part and denied in part a writ of mandamus sought by Charles Summers to compel the production of public records by Mercer County Prosecuting Attorney Matthew Fox and Mercer County Sheriff Jeff Grey, holding that Summers was entitled to a writ of mandamus as to certain requests.Summers pleaded guilty to several counts of sexual battery in violation of Ohio Rev. Code 2907.03. In his public-records request to Mercer County Prosecutor's Office Summers requested several items relating to his criminal prosecution. Summers then requested from the Mercer County Sheriff several other items related to his criminal case. The county denied Summers's requests. Summers then commenced this action. The Supreme Court granted a writ in part, holding that Summers demonstrated by clear and convincing evidence that he had a clear legal right to some of the requested relief, and the county had a clear legal duty to provide that relief. View "State ex rel. Summers v. Fox" on Justia Law

The Supreme Court affirmed Defendant's two aggravated murder convictions and death sentences, holding that no reversible error occurred in the proceedings below.Specifically, the Supreme Court held (1) defense counsel were not ineffective for failing to request a change of venue or in filing a joint motion for a gag order; (2) defense counsel were not ineffective for withdrawing Defendant's plea of not guilty by reason of insanity in Defendant's absence or in failing to request a continuance to obtain additional neuroimaging; (3) defense counsel were deficient for failing to object to certain evidence, but the deficient performance did not result in prejudice; (4) defense counsel made an inappropriate comment during mitigation-phase closing argument, but the comment did not prejudice Defendant; (5) Defendant's remaining ineffective assistance of counsel claims were without merit; (6) the trial court did not err in replacing one juror with an alternate juror; and (7) Defendant's sentences were not unlawful. View "State v. Grate" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that a child-abuse investigator employed by a county children-services agency need not give the warnings required by Miranda v. Arizona, 384 U.S. 436 (1966), before questioning a child suspected of committing child abuse, holding that the questioning in this case violated neither Miranda nor the suspect's federal due process rights.The trial court in this case granted the suspect's motion to suppress, finding that the suspect's statement to the agency had been obtained in violation of his due process rights. The court of appeals reversed. The Supreme Court affirmed, holding that where the evidence demonstrated that the child-abuse investigator who interviewed the suspect was neither a law enforcement officer nor acting under the direction or control of the police and where the suspect's confession was not causally related to any conduct of the police, the court of appeals correctly concluded that the confession resulting from the questioning was admissible at trial. View "In re M.H." on Justia Law