Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed in part the judgment of the court of appeals affirming the judgment of the trial court convicting Defendant of four counts of rape of S.M., his step-daughter, and two counts of rape of J.M., his niece by marriage and six sexually-violent predator specifications, holding that a familial relationship is not a "mental or physical condition" for purposes of Ohio Rev. Code 2907.02(A)(1)(c).On appeal, Defendant argued that the State had not established that his victim's "ability to resist or consent [was] substantially impaired because of a mental or physical condition," Ohio Rev. Code 2907.02(A)(1)(c). The Supreme Court concluded that a familial relationship is not a mental or physical condition, and therefore, it was impossible for the State to prove beyond a reasonable doubt that Defendant violated section 2907.02(A)(1)(c) based on the theory that a familial relationship was the condition that caused the victims' substantial impairment. View "State v. Horn" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting summary judgment to the warden of the Pickaway Correctional Institutional and dismissing Appellant's complaint for a writ of habeas corpus, holding that the court of appeals correctly granted summary judgment to the warden and dismissed Appellant's complaint for a writ of habeas corpus.Appellant, an inmate, filed a complaint for writ of habeas corpus asking the court to order his release from prison. In his complaint, Appellant challenged the actions of the Adult Parole Authority and alleged that because he had not been considered for parole since the completion of his sentence the warden was unlawfully restraining him. The court of appeals granted summary judgment for the warden. The Supreme Court affirmed, holding that Appellant's arguments rested on his mistaken belief that his sentence expired upon the completion of his minimum sentence and that Appellant's complaint for a writ of habeas corpus was correctly dismissed. View "State ex rel. Holman v. Collins" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's second petition for a writ of habeas corpus against the warden of the Chillicothe Correctional Institution, holding that the court of appeals correctly granted the warden's motion to dismiss.In dismissing the petition, the court of appeals concluded that Appellant's claims were not cognizable in habeas corpus and that res judicata barred Appellant's successive habeas corpus petition. Appellant appealed the dismissal and also filed a motion to strike the warden's brief for lack of a valid certificate of service. The Supreme Court affirmed the judgment of the court of appeals and denied the motion to strike, holding that the court of appeals' analysis was correct in both respects and that Appellant presented no evidence to support his motion to strike. View "Green v. Shoop" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's complaint for a writ of mandamus to compel a common pleas court judge to enforce the terms of an agreement the county prosecutor had reached with Appellant's wife to secure her testimony against Appellant, holding that the court of appeals did not err.The court of appeals granted the judge's motion for summary judgment, holding that Appellant was not entitled to mandamus relief because he had an adequate remedy at law and because his claim was barred by the doctrine of res judicata. The Supreme Court affirmed, holding that the court of appeals correctly found that Appellant had a plain and adequate remedy and law and that Appellant's claim was barred by the doctrine of res judicata. View "State ex rel. Phelps v. McClelland" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against two court of common pleas judges, holding that the judges did not have a clear legal duty to provide the relief that Appellant sought.The judges in this case sentenced Appellant after he entered guilty pleas to criminal offenses and ordered him to pay court costs. Appellant filed this petition for a writ of mandamus seeking to compel the judges to vacate their orders imposing court costs and to hold hearings on his ability to pay court costs under Ohio Rev. Code 2947.23. The court of appeals granted the judges' motion to dismiss. The Supreme Court affirmed, holding that Appellant did not have a clear legal right to receive the relief he sought and failed to establish that he lacked an adequate remedy at law by which to challenge the trial courts' determinations. View "State ex rel. Martin v. Russo" on Justia Law

The Supreme Court held in this criminal case that the trial court has the ability to resentence de novo a defendant on a specific count after the sentence related to that count has been vacated on direct appeal and the defendant has been confined for the length of the original prison term that had been attached to that count.Defendant was found guilty of five charges. The court of appeals reversed Defendant's conviction on Count Two and modified two other convictions to reflect lower degrees of the offenses. Upon remand from the Supreme Court, the court of appeals reinstated Count Two but reduced the degree level of the offense. On remand, the trial court resentenced Defendant on Count Two, Count Three, and Count Five. The aggregate sentence after the remand was the same as Defendant's original aggregate sentence. The court of appeal reversed, holding that, by the time Defendant was resentenced, she had already served the original prison term on Count Two and therefore count not be resentenced on Count Two even though she had not completed her sentence for Count Five. The Supreme Court reversed, holding that the trial court had the authority to resentence Defendant de novo on Count Two. View "State v. Christian" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus alleging that the prosecuting attorney failed properly to respond to a public-records request, holding that Appellant did not comply with Ohio Rev. Code 2969.25(A).Appellant, an inmate, filed with his complaint an affidavit listing six civil actions he had filed within the previous five years. The court of appeals concluded that Appellant did not comply with section 2969.25(A)(4) because the affidavit did not provide any information describing the outcome of the actions. The Supreme Court affirmed, holding that the court of appeals correctly dismissed the complaint because Appellant did not strictly comply with section 2969.25. View "State ex rel. Ware v. Walsh" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions for multiple counts of drug trafficking, holding that the warrant issued by a Sandusky County judge that allowed Drug Enforcement Agency agents sitting in Toledo (Lucas County) to listen to cell-phone calls of an alleged drug trafficker who was based in Sandusky County was valid because the government properly obtained the interception warrant in the Sandusky County Common Pleas Court.On appeal, Defendant argued that the warrant was invalid because the calls were intercepted in Toledo when the agents listened to them, and therefore, the warrant was issued by a judge in the wrong county. The Supreme Court disagreed, holding (1) interception occurs both at the place where agents are listening and at the place where the phone is used and (2) Defendant's calls were intercepted - captured and redirected - by law enforcement in Sandusky County where Defendant used his cell phone to facilitate drug trafficking, and therefore, the interception warrant was properly obtained in Sandusky County. View "State v. Nettles" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Appellant's motion for relief from a judgment dismissing his mandamus action against the Ohio Adult Parole Authority and the Bureau of Sentence Computation (collectively, the APA), holding that the court of appeals properly denied Appellant's motion for relief from judgment.In his complaint for a writ of mandamus Appellant, an inmate, alleged that he should have been eligible for parole in 2019 but that the APA had his first hearing scheduled for 2024. The court of appeals dismissed the complaint after adopting the recommendation of the magistrate. Appellant then filed a motion for relief from judgment. The court of appeals denied the motion, ruling that Appellant was barred from asserting that the court of appeals committed any error in adopting the magistrate's decision. The Supreme Court affirmed, holding that Appellant's propositions of law were either waived or without merit. View "State ex rel. Franks v. Ohio Adult Parole Authority" on Justia Law

The Supreme Court reversed Defendant's convictions for aggravated murder and other felonies and the death sentence imposed by the county court of common pleas, holding that Defendant was deprived of his constitutional right to the effective assistance of counsel when defense counsel, during voir dire, failed to question or strike a racially biased juror.On appeal, Defendant presented seventeen propositions of law. In his seventeenth proposition of law, Defendant argued that his trial counsel provided ineffective assistance by failing to question and strike a juror who made racially biased statements on her juror questionnaire and that counsel's deficient performance denied him a fair and impartial jury. The Supreme Court found this issue dispositive and reversed Defendant's convictions and sentence, holding that defense counsel's performance during voir dire was objectively unreasonable and that counsel's deficient performance prejudiced Defendant in violation of his constitutional right to effective assistance of counsel. The Court remanded the case to the trial court for a new trial. View "State v. Bates" on Justia Law