Justia Ohio Supreme Court Opinion Summaries

The case revolves around James E. Mitchell, an inmate serving a 160-year prison sentence for a 1994 conviction in Summit County, which is to be served consecutively to a 3- to 15-year prison sentence imposed for a June 1994 conviction in Portage County. Mitchell filed a petition for a writ of habeas corpus against Warden George A. Fredrick and the Ohio Adult Parole Board, arguing that the Portage County trial court lacked jurisdiction when it sentenced him on his guilty plea to burglary and gross sexual imposition. He claimed that no judgment of conviction and sentence had been imposed on him regarding the indicted offenses of rape and aggravated burglary, rendering his prison sentence void.Mitchell's petition was initially reviewed by the Third District Court of Appeals, which dismissed his petition. The court concluded that Mitchell failed to raise a claim cognizable in habeas corpus and failed to show that his prison sentence had expired. It also noted that Mitchell had adequate remedies in the ordinary course of the law to raise his claims.The case was then reviewed by the Supreme Court of Ohio. The court affirmed the judgment of the Third District Court of Appeals, dismissing Mitchell's petition for a writ of habeas corpus. The Supreme Court found that the Portage County trial court had subject-matter jurisdiction to accept Mitchell’s guilty plea to burglary and gross sexual imposition and to sentence him accordingly. Any defects in the trial court’s sentencing entry were deemed to implicate the trial court’s exercise of jurisdiction over Mitchell’s criminal case, not the court’s subject-matter jurisdiction. The court also noted that Mitchell had adequate remedies, which he pursued. Therefore, the court concluded that the dismissal of Mitchell's petition was correct based on adequate-remedy grounds. View "State ex rel. Mitchell v. Fredrick" on Justia Law

The case involves Damon L. Taylor, who was charged with felony murder in the adult court after the juvenile court found probable cause to believe that Taylor was complicit in a murder. The adult court convicted Taylor of felony murder, but the Tenth District Court of Appeals vacated the conviction, arguing that the adult court lacked jurisdiction to convict Taylor of felony murder as the juvenile court had not found probable cause for that specific offense. The appellate court also ruled that Taylor's statements to the police should have been suppressed as his Sixth Amendment right to counsel had been violated.The Supreme Court of Ohio disagreed with the appellate court's decision. The Supreme Court held that the adult court did have jurisdiction over the felony-murder charge against Taylor. The court reasoned that the felony-murder charge was rooted in the same acts and events as the complicity-to-commit-murder charge, which was the subject of the juvenile complaint. Therefore, under former R.C. 2151.23(H), the adult court had jurisdiction over the felony-murder charge.Regarding Taylor's Sixth Amendment right to counsel, the Supreme Court held that this right did not attach until a criminal prosecution had commenced, which occurred after the police interrogated Taylor. Therefore, the state did not violate Taylor's Sixth Amendment right to counsel when it interviewed him in the absence of his attorney. Even if the Sixth Amendment right to counsel had attached, Taylor validly waived it when he relinquished his Fifth Amendment right to counsel after he received the Miranda warnings.The Supreme Court reversed the judgment of the Tenth District Court of Appeals and remanded the matter to that court for further proceedings. View "State v. Taylor" on Justia Law

The case revolves around Fadi Salem, who was convicted of third-degree-misdemeanor sexual imposition in February 2021. As per Ohio law, this conviction classified him as a Tier I sex offender, requiring him to register and report to the sheriff. However, the judgment entry of conviction did not explicitly state this classification. Salem later filed a motion to terminate his Tier I sex-offender classification and registration requirements, arguing that the initial judgment did not impose this classification. The trial court denied this motion and issued a nunc pro tunc judgment entry designating Salem a Tier I sex offender.Salem appealed the trial court's denial of his motion to the Twelfth District Court of Appeals. The court of appeals upheld the trial court's decision, stating that the trial court had provided Salem with the required notice of his Tier I sex-offender classification and registration requirements during the sentencing hearing. The court also held that the trial court was permitted to issue a nunc pro tunc judgment entry reflecting the imposition of the Tier I classification.While his appeal was pending, Salem filed a complaint for a writ of mandamus in the court of appeals, asking for a writ compelling the sheriff to enforce the initial judgment without the Tier I sanction. The court of appeals dismissed this complaint, stating that Salem's appeal was an adequate remedy that precluded relief in mandamus.The Supreme Court of Ohio affirmed the judgment of the Twelfth District Court of Appeals. The court held that Salem's appeal from the trial court's judgment denying his motion to terminate his Tier I sex-offender classification and registration requirements was an adequate remedy. The court also noted that the fact that Salem's appeal was unsuccessful did not render that remedy inadequate. View "State ex rel. Salem v. Jones" on Justia Law

The case revolves around Deonta Boyd, an inmate at the Richland Correctional Institution, who pleaded guilty in 2006 to aggravated murder with a firearm specification, felonious assault, and aggravated burglary. The trial court accepted Boyd's pleas and sentenced him to life imprisonment with parole eligibility after 41 years. Boyd did not appeal his convictions or sentence but has attempted unsuccessfully to withdraw his guilty pleas multiple times. In March 2023, Boyd filed a complaint for a writ of prohibition, claiming that the trial court violated his rights under the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution and their counterparts in the Ohio Constitution. He alleged that the trial court failed to inform him that he was waiving his constitutional right to compulsory process at the 2006 plea hearing.The Sixth District Court of Appeals dismissed Boyd's prohibition complaint, holding that Boyd could have challenged any defect in the plea colloquy on direct appeal and that any issue concerning the trial court’s alleged failure to advise him of his right to compulsory process is therefore barred by res judicata. Boyd appealed the dismissal of his complaint.The Supreme Court of Ohio affirmed the Sixth District Court of Appeals' judgment. The court found that Boyd had adequate remedies in the ordinary course of the law to raise his claim, including a direct appeal, a petition for postconviction relief, and a motion to withdraw his guilty pleas. The court also found that the trial court did not patently and unambiguously lack subject-matter jurisdiction to convict him. Therefore, Boyd was not entitled to a writ of prohibition, and the Sixth District correctly dismissed the prohibition action. View "State ex rel. Boyd v. Tone" on Justia Law

The case revolves around Derrick Martre, who was arrested in May 2017 for domestic abuse and possession of sexually explicit images of children on his cellphone. The arrest was prompted by a police report filed by Martre’s then-girlfriend, who discovered two videos on Martre’s cellphone showing Martre touching a naked female child. Martre was subsequently indicted on six felonies and sentenced to an aggregate term of 12 years in prison. In March 2021, Martre filed a motion for the return of his seized cellphone and its memory card, arguing that his cellphone was unlawfully seized.The Allen County Court of Common Pleas granted Martre's motion for the return of his property, subject to certain limitations. The court did not address Martre’s contention that the search warrant was void. Martre appealed this decision to the Third District Court of Appeals, arguing that the trial court's order for the return of his property should have also vacated his convictions. The Third District rejected Martre’s argument and affirmed the trial court's decision.Martre then petitioned the Third District for a writ of mandamus against the trial judge and the Allen County prosecutor, asserting that he had a right to a suppression hearing and a right to findings of fact and conclusions of law from the judge. The Third District dismissed Martre’s petition, concluding that Martre had an adequate remedy in the ordinary course of the law to raise his arguments, either through direct appeal or postconviction motions. Martre appealed this decision to the Supreme Court of Ohio. The Supreme Court affirmed the Third District’s judgment, stating that Martre had an adequate remedy in the ordinary course of the law because he could—and did—appeal the trial court's decision. The court also denied Martre’s motion for judicial notice. View "State ex rel. Martre v. Reed" on Justia Law

The case involves appellant Marcus D. White's appeal against the Tenth District Court of Appeals’ judgment dismissing his complaint for a writ of mandamus or procedendo against appellee, Franklin County Common Pleas Court Judge Carl A. Aveni II. White had filed a postconviction petition and a motion in the trial court, which he claimed were not addressed in a timely manner. Judge Aveni responded with a motion to dismiss, arguing that he had not unnecessarily delayed in proceeding.The Tenth District Court of Appeals dismissed White's complaint as moot, based on the trial court's docket entry indicating that the postconviction petition and the motion had been addressed. However, White argued that the docket entry did not constitute a decision on his motion.The Supreme Court of Ohio affirmed in part and reversed in part the Tenth District’s judgment. The court agreed that White's claim regarding his postconviction petition was moot as it had been addressed. However, it disagreed with the lower court's conclusion that the trial court's docket entry itself disposed of the motion. The court clarified that a docket entry was not sufficient to constitute a decision by the judge on the motion. Therefore, the case was remanded to the appellate court for consideration of White's claim regarding his motion.Judge Aveni's motion to declare White a vexatious litigator was denied by the Supreme Court of Ohio, citing a lack of precedent in which the court declared a party a vexatious litigator in a case in which the party prevailed on one of his or her claims. View "State ex rel. White v. Aveni" on Justia Law

The case revolves around Timothy Williams, who was 16 years old when he committed the offense in question. Williams rang the doorbell of Everett and Leslie Lawson's home, pretending to have been injured in a car accident. When Leslie opened the door to help, Williams shot her twice, killing her instantly. Williams was charged in juvenile court for conduct that would constitute murder and felonious assault if committed by an adult. The state did not charge Williams in the juvenile-court complaint for conduct that would constitute tampering with evidence.The juvenile court found probable cause to believe that Williams committed all the offenses and transferred the case to the Hamilton County Court of Common Pleas. A grand jury then indicted Williams for murder, felonious assault, and tampering with evidence. Williams eventually pleaded guilty to involuntary manslaughter and tampering with evidence. He was sentenced to an aggregate 17-year prison term.Williams appealed his tampering-with-evidence conviction to the First District, arguing that his statutory and constitutional rights were violated when he was indicted for and convicted of tampering with evidence, because that charge had not been transferred from the juvenile court to the adult court. The First District, relying on a previous decision, held that the adult court had lacked subject-matter jurisdiction over the tampering-with-evidence charge because the juvenile court had not found probable cause on that charge. The appellate court thus vacated Williams’s tampering-with-evidence conviction.The state appealed to the Supreme Court of Ohio, which reaffirmed its previous holding that a defendant who was a juvenile when he committed an offense may be charged for and convicted of that offense in adult court even though a charge for the offense was not brought in juvenile court and considered in a bindover proceeding, if the charge is rooted in the same acts that were the subject of the juvenile complaint. Consequently, the Supreme Court of Ohio reversed the judgment of the First District Court of Appeals and remanded the matter to that court for it to resolve any remaining assignments of error. View "State v. Williams" on Justia Law

The case revolves around a criminal defendant's right to confront the witnesses against him under the Confrontation Clause of the Sixth Amendment to the United States Constitution. The defendant, Eli Carter, was found guilty of having sexual relations with his adopted daughter. He argued that his right to face-to-face confrontation was violated because the trial court allowed a witness to testify remotely via video conference.The trial court had allowed the remote testimony due to the witness's unavailability to testify in person due to unpredictable winter weather and uncertain airline schedules. The court also noted the state's identification of the witness as important and found his testimony relevant and admissible. The defendant appealed this decision, arguing that the remote testimony violated his constitutional right to confront the witnesses against him.The Third District Court of Appeals rejected the defendant's arguments and affirmed the trial court's judgment. The court of appeals noted that the trial court had found that airline-labor shortages and other causes were creating unprecedented travel delays. The court further stated that even if it were to assume that the possibility of inclement weather was insufficient to warrant an exception for the witness's video testimony, the trial court's determinations were justified on a case-specific finding based on an important public policy involving the COVID pandemic.The Supreme Court of Ohio agreed that the trial court erred by allowing the remote testimony. The court held that the trial court's generalized concerns about COVID-19 risks and travel delays did not constitute a "case-specific finding of necessity," sufficient to abridge the defendant's right to face-to-face confrontation. However, the court also concluded that the trial court's error was harmless given the remaining evidence at trial. The court found that there was no reasonable possibility that the witness's testimony contributed anything to the jury's findings of guilt that it could not have gleaned from other witnesses. Therefore, the court affirmed the judgment of the Third District Court of Appeals, albeit on different grounds than those relied upon by that court. View "State v. Carter" on Justia Law

The Supreme Court of Ohio dealt with an appeal made by an inmate, Albert Townsend Sr., against the Eighth District Court of Appeals' decision denying his complaint for a writ of mandamus. Townsend was previously convicted on several counts of rape and kidnapping, leading to a sentence of 56 years to life in prison and classification as a sexually violent predator. The court of appeals had deemed his sentence faulty concerning two of his victims and remanded the case for resentencing on eight of the counts.In Townsend's mandamus complaint, he alleged entitlement to a resentencing hearing and claimed he should have received the benefit of a purported plea deal offered by the state. However, the court of appeals dismissed his complaint, noting that he had not complied with R.C. 2969.25(C), which mandates an inmate seeking a waiver of the court's filing fee to submit an affidavit of indigency that includes a certified statement of the balance in the inmate's institutional account for the past six months. The court of appeals noted that Townsend's complaint was defective due to noncompliance with this requirement.Upon review, the Supreme Court of Ohio affirmed the court of appeals' decision. They noted that Townsend had indeed failed to comply with R.C. 2969.25(C) and that his provided account statement was neither certified by the institutional cashier nor covered the required six-month period. As Townsend did not argue his compliance with R.C. 2969.25(C) in his appeal, the Supreme Court found no grounds for reversal of the lower court's judgment. View "State ex rel. Townsend v. Gaul" on Justia Law

The case centers on an appeal by the appellant, Gudonavon J. Taylor, who petitioned for a writ of prohibition against the Montgomery County Court of Common Pleas (the trial court). Taylor argued that the trial court had no jurisdiction to convict him of and sentence him for felony murder in 2010. He claimed that the trial court lacked subject-matter jurisdiction to convict him on one of his murder counts. The Second District Court of Appeals dismissed the petition, and Taylor appealed to the Supreme Court of Ohio.The Supreme Court of Ohio affirmed the decision of the Second District Court of Appeals. The court concluded that the trial court had jurisdiction to convict Taylor of felony murder under R.C. 2903.02(B). Even if Taylor's claim that he could not have committed a predicate offense necessary for the conviction was correct, this would have been an error in the exercise of jurisdiction, not in the lack of it. As Taylor was unable to demonstrate that the trial court patently and unambiguously lacked jurisdiction, he was not entitled to a writ of prohibition. The court also denied Taylor's request for oral argument. View "State ex rel. Taylor v. Montgomery Cty. Court of Common Pleas" on Justia Law