Justia Ohio Supreme Court Opinion Summaries

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

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