Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals dismissing the State's appeal from the order of the trial court granting Defendant's motion for a new trial based on insufficient evidence, holding that the court of appeals was not correct in dismissing the State's appeal.The court of appeals premised its dismissal of the State's appeal on principles of double jeopardy and on its application of Ohio Rev. Code 2945.67. The Supreme Court reversed, holding (1) the double jeopardy protection does not prevent the State from appealing the trial court's order granting the motion for a new trial but, rather, only prevents the State from retrying the defendant in the event the State is unsuccessful on appeal; and (2) section 2945.67, which delineates when the State may appeal in a criminal case, does not require dismissal of the State's appeal. View "State v. Ramirez" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court denying Defendant's motion to suppress, holding that a court may consider evidence beyond the four corners of a search warrant affidavit in determining whether an officer reasonably and in good faith relied on that warrant.Defendant was indicted for sexual imposition and voyeurism. Defendant filed a motion to suppress seeking to invalidate a search warrant authorizing the search of his home on the basis that the warrant affidavit contained materially false statements. The trial court ultimately denied the motion to suppress. At issue on remand was whether a detective's testimony regarding his unrecorded conversation with the judge at the time of the approval of the warrant was admissible at the suppression hearing. The court of appeals reversed, holding that the testimony was inadmissible and that the good-faith exception did not apply. The Supreme Court reversed, holding (1) in deciding whether the good-faith exception to the exclusionary rule applies to a search conducted under a search warrant, a court can consider sworn but unrecorded oral information that the police gave to the judge; and (2) because application of the exclusionary rule would not serve to deter any bad police conduct, suppression was unwarranted. View "State v. Dibble" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that reasonable parental discipline is not a component of the physical-harm element on Ohio's domestic violence and assault statues but, rather, is an affirmative defense to a charge under those statutes, holding that reasonable parental discipline is an affirmative defense.Defendant was charged with one third-degree felony count of domestic violence and one first-degree misdemeanor count of assault for allegedly beating the seven-year-old son of his live-in girlfriend for acting out at school. During trial, Defendant argued that his conduct was a reasonable exercise of parental discipline and corporal punishment. The trial court found Defendant guilty of the charges. The court of appeals affirmed, holding that treating reasonable parental discipline as an affirmative defense and placing the burden of proving that defense upon the accused does not violate due process. The Supreme Court affirmed, holding (1) proof of unreasonable parental discipline is not a component of the physical harm element of the offenses; (2) reasonable parental disciplines an affirmative defense; and (3) treating reasonable parental discipline as an affirmative defense does not unconstitutionally place the burden of proof on the defendant. View "State v. Faggs" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against the warden of the Lake Erie Correctional Institution, holding that the court of appeals correctly dismissed Appellant's habeas petition for failure to comply with Ohio Rev. Code 2969.25(A).Appellant filed a petition for a writ of habeas corpus alleging that he was entitled to immediate release from prison because his sentences had expired. The court of appeals dismissed the complaint for failure to comply with section 2969.25(A). Appellant appealed. After briefing was completed, Appellant filed a motion for certified copies of the record. The Supreme Court denied the motion and affirmed the court of appeals' dismissal of the habeas petition, holding that dismissal was proper because Appellant did not comply with section 2969.25(A). View "Robinson v. Fender" 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 the court of appeals properly dismissed the habeas corpus petition.In dismissing the petition, the court of appeals concluded that Appellant had failed to attach all his commitment papers to the petition and failed to state a proper claim for relief in habeas corpus. Further, the court found that the petition was barred under the doctrine of res judicata. The Supreme Court affirmed, holding that Appellant's failure to attach commitment papers related to his convictions was a fatal defect and that Appellant's petition failed to state a claim cognizable in habeas corpus. View "State ex rel. Kerr v. Turner" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's appeal of his conviction for two counts in an indictment because of a "hanging charge," holding that, in this case, the trial court's finding that Appellant was incompetent to stand trial on the pending charge operated as a de facto severance of that count from the counts of conviction.A jury found Appellant guilty on two counts in an indictment and hung on a third count. Appellant was sentenced to imprisonment on the two counts on which he was convicted, but the third count remained pending. Because of the "hanging charge," the court of appeals dismissed Appellant's appeal from his convictions for lack of a final, appealable order. The Supreme Court reversed, holding that when a defendant is convicted and sentenced on fewer than all counts of a multicount indictment and the State is prevented from retrying the defendant on the remaining counts due to a finding that the defendant is incompetent to stand trial, the incompetency finding effectively severs the charges, and the defendant may appeal his or her conviction and sentence. View "State v. Craig" 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 the petition did not comply with the mandatory filing requirements of Ohio Rev. Code 2725.04 and that Appellant's claims were not cognizable in habeas corpus.Appellant was arrested and held in jail on a felony charge. The municipal court scheduled a preliminary hearing but then granted the State's motion for a continuance. Appellant later filed a petition for a writ of habeas corpus against the county sheriff arguing that he was entitled to immediate release because the municipal court had failed to conduct a preliminary hearing within ten days after his arrest and that the continuance was fatally flawed. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant's petition was fatally defective and that Appellant's claims were not cognizable in habeas corpus. View "Davis v. Sheldon" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of prohibition to vacate his criminal convictions, holding that the court of appeals correctly concluded that Appellant's claims were barred by res judicata.Appellant was convicted of four counts of forgery and four counts of tampering with evidence. Appellant later filed a petition for a writ of prohibition against the now-retired judge who presided over his criminal case and the judge who replaced the previous judge, claiming that his judgment of conviction should be vacated because certain evidence was improperly admitted at trial, venue was not properly established, his convictions were not supported by sufficient evidence, and the prosecutor committed misconduct. The court of appeals dismissed the petition sua sponte. The Supreme Court affirmed, holding that the petition was properly dismissed because (1) the common pleas court had subject matter jurisdiction to hear Appellant's criminal case; (2) Appellant's appeal of his criminal convictions constituted an adequate remedy at law; and (3) Appellant's claims were barred by res judicata. View "State ex rel. Kerr v. Pollex" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against the Ohio Department of Rehabilitation and Correction (DRC), holding that the court of appeals correctly dismissed Appellant's complaint for his failure to submit the statement of inmate account required by Ohio Rev. Code 2969.25(C)(1).Appellant, an inmate, filed a petition seeking a writ of mandamus ordering the DRC to aggregate his prison terms "in a manner consistent with the law." The court of appeals dismissed the petition sua sponte because Appellant had failed to comply with section 2969.25(C)(1). On appeal, Appellant argued that he filed with his petition an inmate account statement that substantially with section 2969.25(C). The Supreme Court affirmed, holding that because section 2969.25(C) does not permit substantial compliance the court of appeals correctly dismissed Appellant's complaint. View "State ex rel. Roden v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting summary judgment to Judge Joseph D. Russo and denying Sell Jefferson a writ of mandamus, holding that Jefferson's claims were barred by res judicata.In 1975, Jefferson was convicted of aggravated robbery and aggravated robbery and sentenced to life imprisonment. The Ohio Department of Rehabilitation and Correction was not notified of Jefferson's aggravated murder conviction and life sentence. As a result, the Adult Parole Authority granted Jefferson final release in 1982. In 1985, Jefferson was indicted for several felony counts. Jefferson was convicted and sentenced to a prison term, to be served concurrently with his 1975 sentence. Jefferson raised numerous challenges to his arrest and reincarceration in the 1975 case, without success. Jefferson then brought this proceeding, arguing that his due process rights were violated. The court of appeals concluded that the claims in Jefferson's complaint were barred by res judicata. The Supreme Court affirmed, holding that summary judgment was properly granted. View "State ex rel. Jefferson v. Russo" on Justia Law