Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions for corrupting another with drugs and other offenses but remanding the matter to the trial court for resentencing because the trial court had erred in failing to merge the two convictions for corrupting another with drugs as allied offenses of similar import, holding that the trial court properly instructed the jury on the causation element of the offense of corrupting another with drugs.On appeal, Defendant argued that, when instructing a jury on the causation element of the offense of corrupting another with drugs, the trial court is required to inform the jury that it must find not only that the accused's conduct was the but-for cause of serious physical harm to the victim but also that it was an independently sufficient cause of that harm. The Supreme Court affirmed, holding that because Defendant did not ask the trial court to give that instruction, the propriety of such an instruction was not before the Court in this case. View "State v. Price" on Justia Law

The Supreme Court affirmed the judgment of the Fourth District Court of Appeals dismissing Appellant's complaint for a writ of procedendo against Judge Mark Kuhn of the Scioto County Court of Common Pleas, holding that the dismissal of Appellant's complaint was appropriate under the circumstances.Appellant, an inmate, filed a complaint for a writ of procedendo seeking an order compelling Judge Kuhn to journalize a final judgment of conviction. The Fourth District dismissed Appellant's complaint for lack of jurisdiction. The Supreme Court affirmed on different grounds, holding that the dismissal of Appellant's petition was appropriate because Appellant failed to show a clear legal right to relief in procedendo. View "McDougald v. Kuhn" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus, holding that the court of appeals correctly dismissed the mandamus petition.Appellant pleaded guilty to one count of rape and was sentenced to life imprisonment with parole eligibility after ten years. The trial court later entered a nunc pro tunc judgment of conviction to specify that Appellant's sentence included five years of mandatory postrelease control. Appellant later commenced this mandamus action arguing that his sentence was void. The court of appeals dismissed the action. The Supreme Court affirmed, holding that Appellant had adequate remedies at law that precluded extraordinary relief in mandamus. View "State ex rel. Crangle v. Summit County Common Pleas Court" 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 properly determined that Appellant's claim was barred by res judicata.Appellant pleaded guilty to involuntary manslaughter and aggravated robbery and was later released on parole. The Ohio Parole Board later found that Appellant had violated the conditions of his release and revoked his parole. Later that year, Appellant filed a petition for writ of habeas corpus, which the common pleas court dismissed. Appellant subsequently filed a second petition for writ of habeas corpus alleging that the Parole Board lacked authority to revoke his parole. The court of appeals dismissed the petition, concluding that the claim was barred under the doctrine of res judicata. The Supreme Court affirmed, holding that the court of appeals did not err. View "Jones v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals sua sponte dismissing Appellant's complaint seeking a writ of mandamus to compel Lucas County Court of Common Pleas Judge Dean Mandros to grant him judicial release from prison, holding that Appellant failed to state a valid claim for a writ of mandamus.Appellant, an inmate, filed a motion for judicial release under Ohio Rev. Code 2929.20(C)(2). Judge Mandros denied the motion. Appellant subsequently filed this mandamus action seeking a writ of mandamus ordering Judge Mandros to grant judicial release. The court of appeals sua sponte dismissed the complaint. The Supreme Court affirmed, holding that the proper writ for Appellant's purpose was a writ of habeas corpus. View "State ex rel. Neal v. Mandros" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals in this criminal case, holding that Ohio Rev. Code 2913.61(C)(1) unambiguously allows for the aggregation of multiple theft offenses involving one victim into a single count, regardless of the status of the victim.In connection with multiple alleged incidents of passing fraudulent checks at four separate banks, Defendant was convicted of four counts of theft in violation of Ohio Rev. Code 2913.02(A)(3). In accordance with section 2913.61(C)(1), each theft count aggregated the multiple instances of theft alleged against each respective bank. The court of appeals vacated Defendant's sentences in part and otherwise affirmed. In so doing, the court held that section 2913.61(C)(1) does not limit the aggregation of theft offenses under section 2913.02 to offenses involving victims who are disabled adults, elderly persons, or military persons. The Supreme Court affirmed, holding that the unambiguous language of section 2913.61(C)(1) allows aggregation of theft offenses, regardless of the status of the victim. View "State v. Pettus" on Justia Law

The Supreme Court vacated its earlier judgment granting Relator a writ of mandamus and entered a judgment denying the writ, holding that because a transcript could not be located, the earlier judgment cannot be executed.Relator filed an original action seeking a writ of mandamus to compel Respondent, a former Marion County court reporter, to inform him of the cost to obtain a copy of his 2009 sentencing transcript. The Supreme Court granted the writ. The Court then vacated its judgment, holding that where the only evidence indicating that a transcript of Relator's sentencing hearing existed was the trial court's incorrect statement to that effect, this Court's previous judgment could not be executed. View "State ex rel. Newsome v. Hack" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of mandamus seeking to compel the Ohio Department of Rehabilitation and Correction (DRC) to conduct a hearing concerning an alleged use of force incident, holding that because Appellant did not strictly comply with Ohio Rev. Code 2969.25(A) the court of appeals correctly dismissed his petition.Appellant alleged in his petition that he had suffered injuries when a prison officer used a chemical spray on him while he was incarcerated. The court of appeals granted DRC's motion to dismiss, concluding that Appellant had not satisfied section 2969.25(A). The Supreme Court affirmed, holding that Appellant failed to comply with section 2969.25(A) and that the court of appeals was right to dismiss Appellant's petition. View "State ex rel. Russell v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of habeas corpus for failure to state a claim, holding that the court of appeals did not err.Appellant, an inmate, filed a petition for a writ of habeas corpus alleging that the sentencing judge failed to make the findings required by Ohio Rev. Code 2929.14(C) before imposing consecutive sentences. The court of appeals dismissed the petition, concluding that Appellant's complaint did not state a claim cognizable in habeas corpus. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of law, and therefore, relief was unavailable in habeas corpus. View "McKinney v. Haviland" on Justia Law

The Supreme Court remanded this matter to the trial court to vacate the trial court's decision granting the State's motion to correct Defendant's unlawful sentence eighteen years after the sentence was entered, holding that the State cannot challenge Defendant's voidable sentence through a postconviction motion for resentencing.Defendant pleaded guilty to one count of murder with a three-year firearm specification. Defendant should have been sentenced to an indefinite sentence of fifteen years to life for his murder conviction. The trial court, however, sentenced Defendant to a definite sentence. The State later filed a motion for resentencing. The trial court granted the sentence, and the court of appeals affirmed. The Supreme Court reversed the court of appeals' judgment and remanded the matter for the trial court to vacate the sentencing entry and to reinstate Defendant's original sentence, holding (1) sentences based on an error, including sentences in which a court fails to impose a statutorily mandated term, are voidable if the court imposing the sentence has jurisdiction over the case and the defendant; (2) Defendant's sentence was voidable; and (3) the State cannot challenge a voidable sentence through a postconviction motion for resentencing. View "State v. Henderson" on Justia Law