Justia Ohio Supreme Court Opinion Summaries

In November 1991, a ten-year-old child was kidnapped from her home in Harrison, Ohio, and her body was found days later in Bright, Indiana. Jeffrey Wogenstahl was convicted in 1993 of kidnapping and murdering the child and was sentenced to death by the Hamilton County Court of Common Pleas. The First District Court of Appeals upheld his conviction and sentence, and the Ohio Supreme Court affirmed. Wogenstahl's subsequent petitions for postconviction relief and delayed new-trial motions were denied.Wogenstahl filed a delayed application to reopen his direct appeal nearly 30 years after the original judgment, arguing that his appellate counsel was ineffective for not challenging the trial court's jurisdiction and the constitutionality of R.C. 2901.11(D). The First District Court of Appeals denied the application, concluding that Wogenstahl failed to show good cause for the delay and that his claims were barred by res judicata.The Supreme Court of Ohio reviewed the case and affirmed the lower court's decision. The court held that Wogenstahl did not demonstrate good cause for the nearly 30-year delay in filing his application to reopen. The court also noted that even if good cause had been shown, Wogenstahl's claims were barred by res judicata, as the issue of the trial court's jurisdiction had already been litigated and decided in previous proceedings. The court emphasized that principles of res judicata apply to jurisdictional determinations and that Wogenstahl had ample opportunity to raise his constitutional challenge earlier. View "State v. Wogenstahl" on Justia Law

The appellant, Mario D. Mays, was charged with multiple offenses, including violating a protection order under Ohio Revised Code (R.C.) 2919.27(A) and (B), a fifth-degree felony. The trial evidence showed that Mays had a prior conviction for violating a protection order. The jury found Mays guilty, and the verdict form specified the violation of R.C. 2919.27(A)(1) and (B)(3). Mays did not object to the verdict form, which, due to his prior conviction, elevated the offense to a fifth-degree felony under R.C. 2919.27(B)(3).The Sixth District Court of Appeals affirmed Mays’s conviction and sentence. Mays argued on appeal that the verdict form was insufficient to convict him of a fifth-degree felony because it did not reference the offense level or any aggravating factors, as required by R.C. 2945.75(A)(2). The appellate court, relying on the Ohio Supreme Court’s decision in State v. Pelfrey, concluded that a statutory reference within the verdict form is sufficient to comply with R.C. 2945.75(A)(2). The court noted that the statutory reference provided adequate notice of the offense degree.The Supreme Court of Ohio reviewed the case to determine if a verdict form’s reference to the statutory section mandating a higher-level offense complies with R.C. 2945.75(A)(2). The court held that such a reference does satisfy the statutory requirement. The court concluded that the verdict form’s citation to R.C. 2919.27(B)(3) was sufficient to state the degree of the offense, thus complying with R.C. 2945.75(A)(2). Additionally, the court applied plain-error review, as Mays did not object to the verdict form at trial, and found no plain error affecting Mays’s substantial rights. Consequently, the Supreme Court of Ohio affirmed the judgment of the Sixth District Court of Appeals. View "State v. Mays" on Justia Law

In January 2020, Sontez Sheckles was indicted in Hamilton County Common Pleas Court for attempted murder, felonious assault, and having a weapon while under a disability, stemming from an alleged shooting at a bar. The prosecution intended to call a former federal prosecutor, Zachary Kessler, as a witness and present an edited video of the incident. However, the trial court excluded Kessler's testimony due to the absence of a Touhy letter authorizing him to testify and excluded the video because the bar owner could not authenticate it.The State appealed these rulings to the First District Court of Appeals, arguing that the trial court's decisions had weakened its case to the point of destroying any reasonable possibility of effective prosecution. The First District affirmed the trial court's rulings, agreeing that the absence of a Touhy letter justified excluding Kessler's testimony and that the video could not be authenticated by the bar owner.The State then appealed to the Supreme Court of Ohio, which reviewed whether the Touhy regulations should have been used to prevent Kessler from testifying and whether the trial court's pretrial evidentiary rulings should have been considered preliminary. The Supreme Court of Ohio held that Touhy regulations do not create rights for criminal defendants and cannot be used to exclude testimony from a willing and authorized federal employee. The court reversed the First District's judgment on the Touhy issue and remanded the case to the trial court for further proceedings. The court did not address the finality of the trial court's pretrial evidentiary rulings, vacating that portion of the First District's judgment. View "State v. Sheckles" on Justia Law

In 1976, Prince Charles Cotten Sr. was convicted of aggravated murder and sentenced to death. The conviction included specifications for killing a police officer while attempting to escape apprehension. Following the United States Supreme Court's decision in Lockett v. Ohio, which declared Ohio's death-penalty statute unconstitutional, the Ohio Supreme Court commuted Cotten's sentence to life imprisonment.Cotten filed a complaint for a writ of habeas corpus in the Third District Court of Appeals in July 2023, arguing that his conviction and life sentence were invalid because they were based on an unconstitutional statute. The warden moved to dismiss the complaint, asserting that Cotten's life sentence had not expired and that the sentencing court had jurisdiction. The court of appeals granted the motion to dismiss, concluding that Cotten was imprisoned under a valid judgment from a court with proper jurisdiction and that his life sentence had not expired.The Supreme Court of Ohio reviewed the case and affirmed the court of appeals' dismissal. The court held that Cotten's life sentence was valid and that his arguments regarding the unconstitutionality of his original death sentence and the need for resentencing by a three-judge trial court were without merit. The court also denied Cotten's motion to strike documents attached to the warden's merit brief, which included a 2003 habeas corpus petition filed by Cotten that advanced similar arguments. The court concluded that Cotten's claims were not cognizable in habeas corpus and that the sentencing errors he alleged were not jurisdictional. View "Cotten v. Frederick" on Justia Law

Michael Jones was convicted by a jury of ten drug-trafficking and drug-possession charges. Before the trial, Jones filed a motion to suppress evidence seized from a safe in a house, arguing that the consent to search was invalid and the search warrant for the safe was insufficient. The trial court denied the motion and sentenced Jones to an aggregate prison term of 22 to 24.5 years.Jones appealed to the First District Court of Appeals, arguing ineffective assistance of counsel for not challenging the evidence as coerced and the protective sweep as unconstitutional. The appellate court agreed, finding that Jones's trial counsel had a reasonable basis to challenge the consent and the protective sweep. The court concluded that the failure to raise these arguments constituted deficient performance and prejudiced Jones. The appellate court ordered a limited remand for Jones to file a new motion to suppress and for the trial court to hold a suppression hearing, staying the consideration of Jones’s remaining assignments of error.The Supreme Court of Ohio reviewed the case and determined that it had jurisdiction under Article IV, Section 2(B)(2) of the Ohio Constitution and R.C. 2505.03(A). The court found that the First District did not comply with App.R. 12(A)(1)(a) and (c) because it did not affirm, modify, or reverse the trial court’s judgment and did not decide all assignments of error. The Supreme Court reversed the judgment of the First District, vacated its entry ordering limited remand, and remanded the case to the First District to enter a judgment that complies with App.R. 12. View "State v. Jones" on Justia Law

An inmate at the Marion Correctional Institution, Willard McCarley, submitted a statement alleging sexual assault by a prison doctor. The institutional investigator found the allegation to be false and issued a conduct report accusing McCarley of violating Rule 27, which prohibits giving false information to departmental employees. The Rules Infraction Board (RIB) found McCarley guilty and placed him in disciplinary control for 14 days. McCarley appealed the decision to the warden and the Ohio Department of Rehabilitation and Correction’s (DRC) chief legal counsel, both of whom affirmed the RIB’s decision.McCarley then filed a mandamus action in the Tenth District Court of Appeals, seeking to compel the DRC to vacate the RIB’s decision. He argued that there was no evidence to support the finding that he lied. The court referred the matter to a magistrate, who recommended granting the DRC’s motion for judgment on the pleadings, stating that McCarley failed to show a clear legal right to the relief sought or a clear legal duty on the part of the DRC. The court of appeals initially remanded the case to the magistrate to address the sufficiency of evidence but ultimately adopted the magistrate’s recommendation and denied the writ.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District’s judgment. The court held that McCarley did not demonstrate that the RIB’s guilty finding imposed an atypical and significant hardship or affected the duration of his confinement, which are necessary to establish a constitutionally protected liberty interest. Additionally, the court found that the RIB’s decision was supported by “some evidence,” specifically the “unfounded” finding of the PREA investigation. Therefore, McCarley was not entitled to mandamus relief, and the DRC was entitled to judgment as a matter of law. View "State ex rel. McCarley v. Dept. of Rehab. & Corr." on Justia Law

Damien L. Peterson was convicted of multiple felonies in November 2019, stemming from four armed robberies in Cleveland. He was arrested by Shaker Heights Police in April 2019 and charged with aggravated robbery. His case was transferred to the Cuyahoga County Court of Common Pleas, where he was convicted and sentenced to 39 to 41.5 years in prison. In May 2023, Peterson petitioned the Eighth District Court of Appeals for a writ of prohibition against Judge Sherrie Miday, alleging that she lacked jurisdiction over his case due to procedural errors, including the absence of a preliminary hearing and bindover order from the municipal court.The Eighth District Court of Appeals dismissed Peterson's petition, citing res judicata, as his claims had been previously raised and found meritless. The court also denied his motion for judgment on the pleadings and declared him a vexatious litigator under its local rules due to his repetitive and baseless filings.The Supreme Court of Ohio reviewed the case and affirmed the Eighth District's judgment but for different reasons. The Supreme Court found that Judge Miday did not patently and unambiguously lack jurisdiction over Peterson's criminal case, as the Cuyahoga County Court of Common Pleas has general jurisdiction over felony cases. The procedural issues Peterson raised, such as the lack of a preliminary hearing and bindover order, did not divest the court of its jurisdiction. Additionally, Peterson had adequate remedies in the ordinary course of the law, such as appeals, to address his claims.The Supreme Court also upheld the Eighth District's decision to declare Peterson a vexatious litigator, noting that his repeated filings of the same arguments constituted frivolous conduct. The court concluded that the Eighth District did not abuse its discretion in making this determination. View "State ex rel. Peterson v. Miday" on Justia Law

Marc D. Curtis, an inmate at the North Central Correctional Complex, requested records from the Cleveland Municipal Court Clerk, Earle B. Turner, related to his criminal case. Curtis sought documents including arrest warrants, DNA search warrants, and cellphone search warrants. The clerk provided some documents but withheld others, citing that Curtis, as an inmate, could not access certain records without a judge's approval per R.C. 149.43(B)(8). Curtis filed a mandamus complaint to compel the clerk to produce the remaining records or confirm their nonexistence.The Eighth District Court of Appeals denied Curtis's writ of mandamus. The court relied on an affidavit from Ronald Tabor, the clerk’s assistant director, who stated that the clerk did not possess the requested records. The court found this affidavit sufficient to establish that the records were not in the clerk’s possession and noted that respondents are not required to create or provide access to nonexistent records.The Supreme Court of Ohio reviewed the case and affirmed the Eighth District's judgment. The court held that Curtis failed to provide clear and convincing evidence that the clerk possessed the requested records. The court also denied Curtis's motion to take judicial notice of new documents and granted the clerk's motion to strike certain personal information from the record. The court concluded that the clerk had adequately demonstrated that the requested records were not in his possession, and Curtis did not rebut this evidence. View "State ex rel. Curtis v. Turner" on Justia Law

Elvin Maldonado was convicted in 2019 of multiple counts of felonious assault and discharging a firearm, with accompanying firearm specifications, and was sentenced to nine years in prison and ordered to register as a violent offender. Maldonado successfully appealed, and the Eighth District Court of Appeals remanded the case to the trial court to vacate the firearm specification sentence and the violent offender registration requirement. On remand, the trial court refused to hold a hearing and issued a new sentencing entry as directed.Maldonado appealed again, arguing that he was entitled to a hearing and that the trial court failed to properly calculate his jail-time credit. The Eighth District Court of Appeals identified a conflict between two of its prior decisions on whether a defendant is entitled to a hearing when part of a sentence is vacated. Before the panel issued its decision, the court decided to resolve the conflict en banc. The en banc court held that a defendant does not have a right to a resentencing hearing in such circumstances, and the panel affirmed the trial court’s judgment based on this en banc decision.The Supreme Court of Ohio reviewed the case and agreed that the Eighth District violated App.R. 26(A)(2) by conducting en banc review before the panel decision was released. However, the Supreme Court found that Maldonado was not prejudiced by this procedural error. The court noted that even if a hearing had been held, Maldonado’s sentence would not have changed, as the remand was only to vacate specific parts of the sentence without altering the overall sentence. Consequently, the Supreme Court of Ohio affirmed the judgment of the Eighth District Court of Appeals. View "State v. Maldonado" on Justia Law

Andre M. Yeager, an inmate at the Richland Correctional Institution, represented himself in a trial where he was found guilty of grand theft, breaking and entering, and vandalism. He was sentenced to an aggregate prison term of 39 months. Yeager appealed his convictions to the Eleventh District, arguing that the trial court erred by allowing him to represent himself. The Eleventh District affirmed the trial court’s judgment of conviction.Yeager then filed an action in the Eleventh District, seeking a writ of prohibition to prevent the trial court from enforcing his convictions and a writ of mandamus directing the trial court to vacate his convictions. He claimed that his case was improperly assigned to the trial-court judge, the trial court violated his right to counsel, and the prosecution withheld exculpatory evidence. The Eleventh District dismissed Yeager’s complaint for failure to state a claim upon which relief can be granted.The Supreme Court of Ohio affirmed the Eleventh District Court of Appeals’ judgment. The court found that Yeager had an adequate remedy in the ordinary course of the law to raise his claims, as he had already exercised that remedy by filing a direct appeal from the trial court’s judgment of conviction. The court also found that the trial court did not patently and unambiguously lack jurisdiction. Therefore, Yeager was not entitled to a writ of prohibition precluding the trial court from enforcing his convictions or a writ of mandamus vacating his convictions. View "State ex rel. Yeager v. Lake Cty. Court of Common Pleas" on Justia Law