Justia Ohio Supreme Court Opinion Summaries

The Supreme Court adopted the recommendation of the master commissioner and granted Petitioner's petition for writ of habeas corpus challenging the amount of his pretrial bond, holding that the master commissioner properly stated the facts and applied the law.Petitioner was in jail awaiting trial on multiple charges when he filed his habeas petition. The Supreme Court referred the matter to a master commissioner to conduct a hearing to determine whether Petitioner was being held unlawfully due to an excessive bond. The master commissioner concluded that the $1,000,000 bond on which Petitioner was being held was excessive and recommended modifying the bail to $200,000. The Supreme Court adopted the recommendation and granted the petition for writ of habeas corpus but with certain additional nonfinancial conditions. View "Mohamed v. Eckelberry" 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 was correct in determining that Appellant's petition failed to state a claim cognizable in habeas corpus.Appellant was convicted of several felony drug-related offenses and sentenced to an aggregate term of thirty-two years' imprisonment. Appellant filed a petition for a writ of habeas corpus alleging that insufficient evidence supported his convictions. The court of appeals dismissed the petition on the grounds that it failed to state a claim cognizable in habeas corpus. The Supreme Court affirmed, holding that the court of appeals did not err. View "Carter v. May" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated murder and sentence of death, holding that no prejudicial error occurred in the proceedings below.Specifically, the Supreme Court held (1) the trial court had jurisdiction over the course-of-conduct death-penalty specification; (2) the trial court did not abuse its discretion in admitting evidence relating to the murder; (3) Defendant was not denied his right to an impartial jury due to the seating of certain jurors; (4) the trial court did not deny Defendant his rights to due process and a fair trial by requiring him to wear leg shackles during the trial; (5) the trial court did not err in ruling that an audiovisual-forensics analyst was a lay witness and allowing him to testify; (6) the trial court did not err in admitting Defendant's videotaped phone conversations; (7) the trial court did not err in admitting autopsy photographs into evidence; (8) no plain error occurred from the prosecutor's statements during the mitigation phase of trial; (9) Defendant received effective assistance of counsel; and (10) Defendant's sentence was constitutional. View "State v. Froman" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus on the grounds that his claim lacked merit, holding that Appellant was not entitled to immediate release.Appellant was convicted of felonious assault and sentenced to an indeterminate prison term of eight to twenty-five years in prison. In his habeas corpus petition, Appellant alleged that he had served his prison sentences and was entitled to immediate release. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that because Appellant will not complete his lawfully imposed prison sentences until December 31, 2022, he was not entitled to immediate release. View "State ex rel. Herring v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's habeas corpus petition against the warden of the Marion Correctional Institution (MCI), holding that Appellant's petition was barred by res judicata.Appellant, an inmate at MCI, filed a successive petition for a writ of habeas corpus alleging that his maximum aggregate sentence had expired. The court of appeals dismissed the action, holding that habeas corpus does not lie because Appellant's maximum aggregate sentence will not expire until June 2023 and that the petition was barred by res judicata as a successive habeas petition. The Supreme Court affirmed, holding that the court of appeals properly granted summary judgment on res judicata grounds. View "Dailey v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction for sexually abusing his granddaughter, holding that acquitted-act evidence was admitted for a proper purpose under Evid.R. 404(B).During trial, the trial court allowed the State to introduce "other acts" evidence that Defendant had previously molested his daughter under similar circumstances. Defendant was put on trial for these allegations but was ultimately acquitted. On appeal, Defendant asked the trial court to categorically rule that admitting evidence related to crimes for which a defendant has been acquitted violates the Double Jeopardy Clause of the Ohio Constitution. The Supreme Court rejected the challenge, holding (1) the Double Jeopardy Clause does not impose a per se bar to the use of other-acts evidence for which the defendant was previously acquitted; and (2) because Defendant placed his intent at issue, the trial court properly admitted evidence of the prior sexual-assault allegations. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing Defendant's convictions of two counts of rape, holding that the trial court erred by admitting "other acts" evidence that Defendant had sexually abused his stepdaughter when she was a child.Defendant was convicted of raping an adult female acquaintance. During trial, the trial court allowed the State to present evidence that Defendant had victimized his former stepdaughter as a child. The court of appeals reversed Defendant's convictions, concluding that the evidence of Defendant's abuse of his stepdaughter constituted improper other-acts evidence and was inadmissible under Evid.R. 404(B). The Supreme Court affirmed, holding that the evidence of Defendant's other acts constituted improper propensity evidence, and the trial court erred in admitting it. View "State v. Hartman" on Justia Law

The Supreme Court granted a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction and its director (collectively, DRC) to revise their calculation of Charles Fraley's prison sentence, holding that Fraley was entitled to a writ of mandamus compelling DRC to correct its records.In this case, the sentencing court imposed an aggregate sentence of ten years. However, DRC computed Fraley's sentence to be an aggregate term of thirteen years. In his petition for a writ of mandamus Fraley argued that DRC was under a clear legal duty to follow the sentencing judge's entries. The Supreme Court agreed, holding (1) Fraley did not have an alternative remedy that would preclude the possibility of a writ of mandamus; and (2) DRC had a clear legal duty to carry out the sentence that the trial court imposed. View "State ex rel. Fraley v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's petition for a writ of mandamus and declared Appellant to be a vexatious litigator under S.Ct.Prac.R. 4.03(B), holding that the court of appeals was correct in denying the writ and that Appellant was a vexatious litigator.Appellant was convicted of three counts of aggravated robbery with firearm specifications and sentenced to more than thirty years in prison. Appellant later filed a petition for writ of mandamus seeking to compel Judge Lindsay Navarre to resentence him. The court of appeals concluded that Appellant had an adequate remedy in the ordinary course of law and denied the writ. The Supreme Court affirmed, holding (1) Appellant had an adequate remedy in the ordinary course of law; and (2) Appellant's raising of repetitive and unmeritorious arguments that this Court had already rejected was frivolous conduct under S.Ct.Prac.R. 4.03(A) and (B). View "State ex rel. Hill v. Navarre" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's judgment denying jail-time credit for the days Defendant was on postconviction house arrest and postconviction electronic monitoring, holding that Defendant was not entitled to jail-time credit for these days.Defendant pled guilty to a charge involving criminal gang activity and was sentenced to community-control sanctions. Defendant was later placed on house arrest after he violated terms of his community control and was then placed on electronic monitoring after new charges were brought against him. During a hearing, Defendant filed a motion asserting that he was entitled to jail-time credit for the time he was on standard house arrest and electronic monitoring. The trial court denied the motion and imposed a sentence. The appellate court reversed, concluding that Defendant was entitled to jail-time credit for the time he was on house arrest and electronic monitoring. The Supreme Court reversed, holding that Ohio Rev. Code 2969.191(A) is plain and unambiguous, limits a jail-time credit to specific types of confinement, and does not provide for a reduction in sentence for a term of postconviction house arrest or electronic monitoring imposed for violating community-control sanctions. View "State v. Reed" on Justia Law