Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals vacating Defendant's conviction and sentence and reinstated the trial court's acceptance of Defendant's plea of no contest to sexual battery, holding that the trial court did not completely fail to comply with Crim.R.11(C)(2)(a), and there was nothing in the record to support a conclusion that Defendant would not have entered his plea had the trial court been more detailed in its explanation. On appeal, Defendant sought to vacate his plea of no contest, arguing that his plea was invalid because the trial court erred by not explaining more fully the obligations and restrictions that went with his status as a sex offender, in violation of Crim. R. 11(C)(2)(a). The court of appeals vacated the conviction without requiring Defendant to show prejudice, concluding that the trial court had completely failed to comply with Crim. R. 11(C)(2)(a). The Supreme Court reversed, holding (1) the trial court did not completely failed to comply with Crim R. 11(C)(2)(a)'s maximum-penalty-advisement requirement; and (2) because Defendant did not establish prejudice, he was not entitled to have his no-contest plea vacated for a failure to comply with Crim.R. 11(C). View "State v. Dangler" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus seeking to compel Cuyahoga County Court of Common Pleas Judge Nancy Margaret Russo to vacate the consecutive prison sentences imposed on Appellant in 1987, holding that Appellant had an adequate remedy at law and was barred from asserting additional claims of sentencing error he could have raised in his previous mandamus action.In 1987, Appellant was convicted of four counts of rape and one count of kidnapping. Appellant was sentenced to prison terms of fifteen to twenty-five years for each of the five counts, to be served consecutively. In 2019, Appellant sought a writ of mandamus to compel Judge Russo to vacate his consecutive sentences. The court of appeals dismissed the writ action, concluding that res judicata barred Appellant's claim and that his prior appeals were an adequate remedy at law to address the alleged defect in his consecutive sentences. The Supreme Court affirmed, holding that Appellant was not entitled to a writ of mandamus in this case. View "State ex rel. Nelson v. Russo" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's original action seeking a writ of procedendo and/or mandamus to compel Hamilton County Court of Common Pleas Judge Melba Marsh to issue a corrected sentencing entry, holding that the court of appeals correctly dismissed the petition as moot.Appellant was convicted of murder with a repeat-violent-offender specification. Appellant later asked the trial court to correct his sentence, arguing that he had improperly been sentenced to postrelease control. On remand, Judge Marsh vacated the postrelease-control sentence. Appellant appealed that order. The court of appeals noted that the trial court had not set forth all the information required under Crim.R. 32(C) in a single document and dismissed the appeal for lack of a final, appealable order. Appellant then filed this original action seeking to compel Judge Marsh to issue a corrected sentencing entry that constitutes a final, appealable order. Judge Marsh issued a nunc pro tunc sentencing entry that constituted a final, appealable order. The court of appeals then dismissed the petition as moot. The Supreme Court affirmed, holding that because Judge Marsh performed the act Appellant requested, the court of appeals dismissed the petition as moot. View "State ex rel. Roberts v. Marsh" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals upholding Defendant's convictions of four counts related to two specific instances of sexual abuse of D.S., holding that the trial court and court of appeals correctly applied Ohio's rape-shield law and determined that evidence of D.S.'s prior nonconsensual sexual assault was inadmissible.On appeal, Defendant asserted that the trial court erred in prohibiting him from introducing evidence during trial that D.S. had previously been sexually assaulted by another person, arguing that the rape-shield law applies only to an accuser's prior consensual sexual activity. The lower court held that Ohio's rape-shield law addresses all sexual activity, not only consensual sexual activity. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the plain meaning of the term "sexual activity" as used in the rape-shield law includes both consensual and nonconsensual sexual activity; and (2) therefore, all sexual activity is barred from admission into evidence by the rape-shield, absent certain exceptions listed in the law. View "State v. Jeffries" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against Holmes County Court of Common Pleas Judge Robert D. Rinfret, holding that the court of appeals correctly determined that Appellant had an adequate remedy in the ordinary course of the law.Appellant, who was serving consecutive prison terms for five convictions, filed a petition for a writ of mandamus arguing that Judge Rinfret improperly sentenced him to a prison term of nine years for his attempted rape conviction instead of the maximum term of eleven years. The court of appeals dismissed the petition, determining that Appellant had failed to file a mandatory affidavit of his prior civil actions and had an adequate remedy in the ordinary course of the law. The Supreme Court affirmed, holding that relief in mandamus was not available because Petitioner had an adequate remedy in the ordinary course of the law. View "State ex rel. Steiner v. Rinfret" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's request for a writ of prohibition and/or mandamus against Montgomery County Court of Common Pleas Judge E. Gerald Parker Jr., holding that the court of appeals correctly determined that Appellant's claim was barred by res judicata.Appellant sought a petition for writ of prohibition and/or mandamus against Judge Erik Blaine, the successor to the judge who sentenced Appellant, alleging that the sentencing court patently and unambiguously lacked jurisdiction to sentence him. Judge Parker, who had succeeded Judge Blaine, subsequently filed a motion for summary judgment. The court of appeals granted summary judgment for Judge Parker, concluding that Appellant failed to demonstrate that the sentencing court patently and unambiguously lacked jurisdiction or that he lacked an adequate remedy at law and that res judicata barred Appellant's claim. The Supreme Court affirmed, holding that Appellant's claim was barred by res judicata. View "State ex rel. Kendrick v. Parker" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against former Lorain County Court of Common Pleas Judge Thomas W. Janas, holding that Appellant's complaint sufficiently alleged that the judge patently and unambiguously lacked jurisdiction to change Appellant's sentence after the sentence had been affirmed on appeal.In 1994, following Appellant's conviction for aggravated murder, the trial court sentenced Appellant to life in prison with parole eligibility after twenty years. In 2018, the Adult Parole Authority informed Appellant that the trial court had issued a nunc pro tunc entry in 1999 stating that Appellant's sentence for aggravated murder was twenty full years to life. In 2019, Appellant filed a complaint for a writ of mandamus arguing that the trial court patently and unambiguously lacked jurisdiction to issue the nunc pro tunc entry after the court of appeals had affirmed his sentence. The court of appeals dismissed the complaint. The Supreme Court reversed, holding that Appellant's complaint stated a meritorious claim that the trial court patently and unambiguously lacked jurisdiction to change his sentence after his sentence had been affirmed on appeal. View "State ex rel. Davis v. Janas" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against the Trumbull Correctional Institution and Julie Loomis, the assistant to the warden (collectively, TCI), holding that the appellate court erred in dismissing Appellant's public-records mandamus complaint.While incarcerated at the Trumbull Correction Institution, Appellant submitted a handwritten public-records request to TCI seeking legal-mailroom logs and the dates and times that the institutional inspector made rounds in the housing units for certain periods. Loomis provided copies of the portions of the requested legal-mailroom logs in which Appellant's name appeared but none of the remaining records. Appellant filed a complaint seeking to compel TCI to provide him with the rest of his requested records. The court of appeals dismissed the complaint, determining that the complaint was moot because Appellant had already received all the requested records to which he was entitled. The Supreme Court reversed, holding that where TCI provided no evidence demonstrating that it complied with the second part of Appellant's records request, the court of appeals erred when it concluded that Appellant's claim was moot. View "State ex rel. Parker Bey v. Loomis" 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 Appellant was not entitled to relief on any of his three propositions of law.Appellant was convicted of an aggravated murder that he committed when he was a juvenile. In his habeas petition, Appellant argued that he was entitled to immediate release because the court of common pleas had lacked subject matter jurisdiction over his case for several reasons. The court of appeals dismissed the complaint, determining that the premise of Appellant's claim was false. The Supreme Court affirmed, holding that the court of appeals properly found that the judgment of conviction and sentence were not void ab initio for lack of subject matter jurisdiction. View "Stever v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for writs of mandamus and procedendo to compel the court of common pleas judge to issue a judgment of conviction that constitutes a final, appealable order, holding that Appellant had an adequate remedy at law.In 1993, Appellant was convicted of aggravated murder with a firearm specification and other offenses. The court of appeals reduced the aggravated murder conviction to a murder conviction. In 1995, on remand, the trial court entered a modified judgment. Appellant later filed a motion arguing that the modified judgment entry was not a final, appealable order because it did not comply with Crim.R. 32(C). The trial court denied the motion. The court of appeals dismissed the appeal. In 2015, the trial court issued a new judgment of conviction sua sponte. Appellant did not appeal from the new entry. In 2018, Appellant filed an action seeking writs of mandamus and procedendo, arguing that the 2015 judgment of conviction was not a final, appealable order. The court of appeals dismissed the petition, concluding that Appellant had an adequate remedy at law. The Supreme Court affirmed, holding that the court of appeals properly dismissed the petition. View "State ex rel. Bonner v. Serrott" on Justia Law