Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the court of appeals finding that Defendant's conviction was against the manifest weight of the evidence and reducing her conviction to a lesser included offense rather than ordering a new trial, holding that a new trial is the appropriate remedy when a reviewing court determines that a criminal conviction is against the manifest weight of the evidence.After a bench trial, Defendant was found guilty of assaulting a peace officer. On appeal, the court of appeals determined that Defendant's conviction was against the manifest weight of the evidence, but rather than ordering a new trial, the court of appeals modified the judgment to reduce the conviction to the lesser included offense of disorderly conduct. The Supreme Court reversed, holding that the court of appeals erred by not adhering precedent dictating that a new trial is the appropriate remedy when a reviewing court determines that a criminal conviction is against the manifest weight of the evidence. View "State v. Fips" on Justia Law

The Supreme Court reversed the judgment of the court of appeals and reinstated Defendant's guilty pleas and convictions, reaffirming that trial courts in felony cases must strictly comply with the plea colloquy required by Crim.R. 11(C)(2)(c) and holding that a trial court strictly complies with Crim.R. 11(C)(2)(c) when it orally advises the defendant in a manner reasonably intelligible to the defendant that the plea waives the rights enumerated in the rule.At issue in this case was whether strict compliance with Crim.R. 11(C)(2)(c) requires that the plea colloquy include particular words. Defendant pleaded guilty to certain crimes. On appeal, Defendant argued that the pleas should be vacated because the trial court failed to ensure that he understood that by pleading guilty he was waiving the constitutional rights enumerated in Crim.R. 11(C)(2)(c). The court of appeals vacated Defendant's guilty pleas and reversed his convictions, concluding that the trial court failed to strictly comply with Crim.R. 11(C)(2) by failing to advise Defendant that he would waive his constitutional trial rights by pleading guilty. The Supreme Court reversed, holding that the trial court strictly complied with Crim.R. 11(C)(2)(c) by using easily understood words conveying to Defendant that he would be waiving certain constitutional rights if he were to plead guilty. View "State v. Miller" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus, holding that Appellant's claim was barred by res judicata.Appellant was convicted of aggravated murder with two firearm specifications. The indictment had contained a count of having a weapon while under disability (WUD), but the court's sentencing entry did not refer to the WUD charge. Appellant later filed a motion for a final, appealable order, arguing that the sentencing entry was void because it failed to dispose of the WUD charge. The trial court denied the motion. Appellant then filed a complaint for a writ of mandamus arguing that the sentencing entry did not dispose of the WUD charge and was not a final, appealable order. The court of appeals dismissed the complaint because Appellant had an adequate remedy in the ordinary course of the law and because Appellant's claim was barred by res judicata. The Supreme Court affirmed, holding that res judicata barred Appellant's mandamus claim because he had raised the same claim multiple times previously. View "State ex rel. Peoples v. Schneider" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing as moot Appellant's complaint for writs of mandamus and procedendo against Clark County Court of Common Pleas Judge Richard J. O'Neill, holding that the court of appeals correctly determined that Appellant's claims were moot.Appellant was found guilty in consolidated cases of murder with a firearm specification and attempted aggravated burglary. Appellant later filed under both case numbers a motion to vacate his postrelease control and a motion for a final, appealable order. The trial court denied the motion for a final, appealable order and granted in part the motion to vacate postrelease control, but the judgment entry did not refer to the motions that Appellant had filed in one of the two cases. Appellant filed a complaint for writs of mandamus and procedendo, arguing that Judge O'Neill had not yet ruled on his motions. Judge O'Neill filed a motion to dismiss, attaching a nunc pro tunc sentencing entry in which the judge effectively denied Defendant's motion to vacate his postrelease-control sentence in the second case. The court of appeals dismissed the claims as moot. The Supreme Court affirmed, holding that Appellant's claims were moot. View "State ex rel. Hibbler v. O'Neill" on Justia Law

The Supreme Court granted Wood County Prosecuting Attorney Paul Dobson's request seeking a peremptory writ of prohibition against Judge Peter Handwork, who presided in two criminal cases finding Andrew Schuman guilty of seven felony counts and who later modified the judgment of sentence, holding that Judge Handwork patently and unambiguously lacked jurisdiction to issue the postjudgment orders.After entry of the judgment of sentence and Schuman's appeal was filed, Judge Handwork considered two motions filed by Schuman and issued two orders modifying the judgment of sentence. Dobson sought a writ of prohibition to vacate the post judgment orders and to prohibit any further exercise of jurisdiction by Judge Handwork. Because Judge Handwork did not file an answer, Dobson also filed a motion for default judgment. The Supreme Court granted the motion for default judgment and issued a peremptory writ of prohibition, holding that Handwork's absence of jurisdiction was patent and unambiguous. View "State ex rel. Dobson v. Handwork" on Justia Law