Justia Ohio Supreme Court Opinion Summaries

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

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