Justia Ohio Supreme Court Opinion Summaries

The Supreme Court dismissed this appeal brought by Appellant challenging the court of appeals' denial of his motion to certify a conflict, holding that this Court lacked the authority to review of the court of appeals' decision.Appellant was serving sentences for seven rape convictions when he filed a petition in the Second District Court of Appeals for a writ of prohibition and/or mandamus alleging that the trial judge in his case patently and unambiguously lacked jurisdiction to sentence him for one of the offenses. The Second District granted summary judgment for the judge. The Supreme Court affirmed. Appellant, in the meantime, filed a motion asking the Second District to certify that its judgment conflicts with other appellate decisions. The Second District denied the motion. The Supreme Court affirmed, noting that the Court lacks the authority to review a court of appeals' decision declining to certify the existence of a conflict. View "State ex rel. Kendrick v. Parker" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that it lacks original jurisdiction over declaratory judgment actions and dismissing the City of East Cleveland's petition for declaratory judgment sua sponte, holding that it is well settled that courts of appeals lack original jurisdiction over claims for declaratory judgment.The City of East Cleveland brought criminal charges against Randolph Dailey and Patricia Coleman, both of whom were sergeants in the Cleveland police department. A jury found Coleman not guilty. In an attempt to obtain review of the trial court's evidentiary rulings before Dailey went to trial, East Cleveland filed a petition for declaratory judgment. The court of appeals dismissed the case for lack of jurisdiction. The Supreme Court affirmed, holding that the court of appeals lacked original jurisdiction over the City's claim for declaratory judgment. View "State ex rel. City of East Cleveland v. Dailey" on Justia Law

The Supreme Court affirmed the judgment of the First District Court of Appeals holding that the trial court erred in allowing the state to strike a juror from the panel after the state had waived its final peremptory challenge, holding that while the appellate court incorrectly required Defendant to demonstrate that the error affected the outcome of the trial, the appellate court's error was itself harmless.On appeal, Defendant argued that the trial court's error in allowing the state to exercise a peremptory challenge out of sequence was structural in nature and therefore per se reversible. The First District held (1) the error was not a constitutional error and therefore could not amount to a structural error, and (2) the error was harmless because Defendant had failed to demonstrate that he had been prejudiced by it. The Supreme Court affirmed, but on different grounds, holding (1) the First District correctly concluded that the error was not structural; (2) the First District erred in failing to require the state to demonstrate that the error did not affect the outcome of the trial court proceedings; and (3) because allowing the state to exercise an additional peremptory strike did not affect the outcome of Defendant's trial, the appellate court's error was harmless. View "State v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the Sixth District Court of Appeals dismissing Appellant's petition seeking habeas relief, holding that the Sixth District correctly dismissed the petition.Appellant was convicted of multiple crimes and sentenced to an aggregate prison term of twenty-one years. After his convictions and sentences were affirmed on direct appeal Appellant filed a petition for a writ of habeas corpus asserting several grounds for relief. The Sixth District dismissed the petition, and the Supreme Court affirmed. The next year, Appellant filed a second petition seeking habeas relief. The Sixth District dismissed the petition, concluding that Appellant's claims were barred under the doctrine of res judicata and that Appellant had an adequate remedy at law. The Supreme Court affirmed, holding that res judicata barred Appellant's successive habeas corpus petition. View "Dixon v. Bowerman" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that a conviction for failure to register as a sex offender under Ohio Rev. Code 2950.04 does not violate a defendant's due-process and jury-trial rights guaranteed by the state and federal Constitutions when the duty to register arises from a juvenile court's delinquency adjudication, holding that such a conviction is not unconstitutional.Appellant was adjudicated delinquent as to what would have been two counts of fourth-degree felony gross sexual imposition if committed by an adult. Appellant was classified as a juvenile-offender registrant and tier I sex offender and was ordered to comply with statutory registration, notification-of-address-change, and verification duties for a period of ten years. Appellant was later convicted for violating a duty to register as a sex offender. On appeal, Appellant argued that his conviction was unconstitutional based on State v. Hand, 73 N.E.3d 448 (Ohio 2016). The court of appeals affirmed. The Supreme Court affirmed, holding (1) that Appellant's conviction for a violation of section 2950.04 for that arose from a juvenile adjudication did not violate Appellant's rights to a jury or due process under the Ohio Constitution and United States Constitution. View "State v. Buttery" on Justia Law

The Supreme Court realigned its precedent in cases involving the imposition of postrelease control with the traditional understanding of what constitutes a void judgment, holding that where a common pleas court has subject matter jurisdiction over the case and personal jurisdiction over the accused any error in the exercise of its jurisdiction in failing to properly impose postrelease control renders the judgment of conviction voidable, not void.Defendant pleaded guilty to robbery as a third-degree felony. The trial court sentenced Defendant to three years imprisonment and imposed a mandatory three-year term of postrelease control. The court, however, did not include the consequences of a violation of postrelease control in the sentencing entry as required by State v. Grimes, 85 N.E.3d 700 (Ohio 2017). Defendant later moved to vacate the postrelease control portion of his sentence, alleging it was void under Grimes. The trial court denied the motion. The court of appeals remanded the case to the trial court for further proceedings to correct the entry imposing postrelease control. The Supreme Court reversed, holding that when the sentencing court has jurisdiction to act, sentencing errors in the imposition of postrelease control render the sentence voidable, not void, and the sentence may be set aside if successfully challenged on direct appeal. View "State v. Harper" on Justia Law

The Supreme Court reversed the judgment of the court of appeals granting Appellant's petition for a writ of mandamus against Judge John W. Rudduck of the Clinton County Court of Common Pleas, holding that Appellant had an adequate remedy at law that precluded extraordinary relief.In 1993, Appellant was convicted of aggravated murder and other crimes. In 2019, Appellant filed a motion for a final appealable order in the court of common pleas, arguing that the trial court did not properly journalize his convictions in a single docket. Judge Rudduck denied the motion. Appellant then filed his petition for a writ of mandamus. The court of appeals granted the petition and ordered Judge Rudduck to file a nunc pro tunc entry to bring the judgment of conviction in Appellant's 1993 criminal case into compliance with Crim.R. 32(C). The Supreme Court reversed, holding that the court of appeals erred in granting a writ of mandamus because Appellant had an adequate appellate remedy in the ordinary course of law. View "State ex rel. Haynie v. Rudduck" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus against the warden of the North Central Correctional Complex, holding that the complaint failed to state a cognizable claim in habeas corpus.Specifically, the Supreme Court held that the district court correctly found that Appellant's sentence was not void and correctly rejected Appellant's claim that the trial court lacked subject-matter jurisdiction. Further, the Supreme Court denied Appellant's motions for judicial notice, holding that the Court was precluded from granting judicial notice. View "State ex rel. Harris v. Turner" on Justia Law

The Supreme Court denied a writ of mandamus sought by Relator to compel Respondent, the public-records custodian at the Southern Ohio Correctional Facility (SOCF), to provide Relator with three public records and to pay Relator statutory damages and court costs associated with this litigation, holding that Relator was not entitled to either a writ of mandamus nor statutory damages.When Relator was an inmate at SOCF he submitted a public-records request to Respondent seeking three documents. Respondent provided one of the three documents. Relator then filed a complaint for a writ of mandamus seeking an order compelling Respondent to provide the two documents and to pay statutory damages and court costs associated with this litigation. The Supreme Court denied the writ of mandamus on the merits, holding that Respondent's response to Relator fully satisfied Respondent's obligations under Ohio Rev. Code 149.43, and therefore, Relator was not entitled a writ of mandamus, and there was no basis to award statutory damages. View "State ex rel. McDougald v. Greene" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals denying Appellant's complaint for a writ of mandamus to compel the Cuyahoga County Clerk of Courts to produce various court records and denying the clerk's request that Appellant be declared a vexatious litigator, holding that the court of appeals erred in denying Appellant's complaint on the grounds that he did not invoke the Rules of Superintendence as the basis for his request.Appellant sought copies of journal entries from his criminal case and a copy of the clerk of courts' records-retention schedule. The clerk largely denied the request. Appellant then filed a complaint for a writ of mandamus. The court of appeals denied Appellant's request for mandamus relief, concluding that the clerk had no clear legal duty to provide the requested records. The Supreme Court reversed, holding (1) this action to compel the production of journal entries from a 1995 case was properly brought under the Public Records Act; and (2) this Court declines to impose sanctions on Appellant or to declare him a vexatious litigator. View "State ex rel. Parker Bey v. Byrd" on Justia Law