Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's denial of Corey Parker's petition for postconviction relief, holding Ohio Rev. Code 2953.23(A) does not vest a common pleas court with authority to grant relief on an untimely or successive petition for postconviction relief when that petition asserts a claim based on a new state or federal right recognized by the Ohio Supreme Court.In 2011, Parker pleaded guilty to criminal offenses. Parker later moved to vacate his mandatory sentence of eight years in prison, arguing that enhancing his adult sentence based on a prior juvenile-delinquency adjudication was unconstitutional. The court of appeals construed the motion to vacate as a petition for postconviction relief and reversed the trial court's denial of relief, concluding that Parker established that he was unavoidably presented from presenting his claim for relief until 2016. Implicit in the court's analysis was the determination that the statutory bar on untimely or successive petitions did not apply. The Supreme Court reversed, holding that none of the exceptions for an untimely or successive petition for postconviction relief applied in this case. View "State v. Parker" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's request for a writ of mandamus against Ohio Department of Rehabilitation and Correction officials (DRC), holding that Appellant failed to establish that he was entitled to a writ of mandamus.In his complaint Appellant sought to compel the removal of information from his legal file before his next parole-board hearing. The court of appeals denied the writ. The Supreme Court affirmed and denied as moot Appellant's motion to grant judgment in his favor, holding that Appellant's arguments on appeal were without merit. View "State ex rel. Robinson v. Chambers-Smith" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Appellant's petition for a writ of habeas corpus against the warden of the Lebanon Correctional Institution, holding that the court of appeals correctly denied the writ of habeas corpus.Appellant was convicted of the rape and sexual battery of his wife's granddaughter. Appellant later filed a petition for a writ of habeas corpus alleging that his convictions were void for lack of subject-matter jurisdiction. The court of appeals determined that Appellant's claims were barred by res judicata and denied the writ on that basis. The Supreme Court affirmed, holding that Appellant was not entitled to habeas corpus relief. View "State ex rel. Whitt v. Harris" on Justia Law

In these consolidated appeals the Supreme Court affirmed the judgments of the court of appeals dismissing Appellant's petition for a writ of mandamus and second petition for a writ of mandamus, holding that even if the dismissals were based on an erroneous rationale, the dismissals were proper.Defendant was found guilty of several offenses. The court of appeals affirmed the convictions and sentence. Defendant later filed a petition for a writ of mandamus claiming that the trial judge had a legal duty to charge him by way of criminal complaint and that the common pleas court lacked subject matter jurisdiction because a criminal complaint was not filed. In his second mandamus petition Appellant sought an order to compel the trial judge to hold a new sentencing hearing and issue a new order dismissal all but one of his convictions. The court of appeals dismissed both petitions, concluding that Appellant's claims were barred by res judicata. The Supreme Court affirmed, holding that even if the court of appeals erred in granting the motions to dismiss based on res judicata the dismissals were proper because Appellant had an adequate remedy in the ordinary course of law. View "State ex rel. Sands v. Culotta" on Justia Law

The Supreme Court granted in part and denied in part Relator's request for a peremptory writ in mandamus seeking to compel responses to a request for public records, holding that Larry Greene, the public-records custodian for the Southern Ohio Correctional Facility, was required to provide Relator copies of requested pages of a legal-mail log, if they existed.Relator, an inmate, submitted a public-records request to Greene seeking a legal-mail log for February 27, 2019 and a copy of an envelope containing legal mail from the federal district court from that same date. Greene did not produce any documents. Relator then commenced this action for a writ of mandamus. The Supreme Court granted the motion in part and denied it in part, holding (1) because Greene did not dispute that if the institution maintained a log of incoming mail that log would qualify as a public record, Greene is ordered to provide the requested records; and (2) because the institution does not maintain the original envelopes enclosing incoming mail, Greene has no responsive documents to this request. View "State ex rel. McDougald v. Greene" on Justia Law

The Supreme Court reversed the judgment of the court of appeals and held that, unless otherwise authorized by statute, a trial court may not impose community-control sanctions on one felony count to be served consecutively to a prison term imposed on another felony count.Defendant pleaded guilty to three counts of unlawful sexual conduct with a minor. On two of the counts the court ordered Defendant to serve a five-year prison term, with each term to run consecutively to the other. On the third count, the court ordered Defendant to serve a five-year term of community control to be served consecutively to the prison terms imposed on the other two counts. The court of appeals affirmed the sentence. The Supreme Court reversed, holding that there was no statutory basis for ordering that a defendant be assessed for placement in a community-based correctional facility after that defendant's completion of a prison term imposed for another offense in that case. View "State v. Hitchcock" 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 Marion Correctional Institution, holding that Appellant's noncompliance with Ohio Rev. Code 2969.25(C) was a sufficient reason to dismiss the petition.The court of appeals dismissed the petition because Appellant, an inmate, had failed to submit an inmate-account statement, as required by section 2969.25(C), and because it was clear that Appellant was not entitled to immediate release. The Supreme Court affirmed, holding that the court of appeals correctly dismissed Appellant's petition for noncompliance with section 2969.25(C). View "State ex rel. Ellis v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's action seeking a writ of mandamus to compel Judge Christine Croce to vacate his sentences, merge certain offenses, and resentence him, holding that Appellant could have raised his claims by appealing his sentence.Appellant pleaded guilty to aggravated burglary, felonious assault, rape and kidnapping. Finding that Appellant's offenses were separate and should not be merged at sentencing the trial court imposed a prison term for each offense and ordered the terms to be served consecutively. Appellant later filed his mandamus action. The court of appeals dismissed the complaint, determining that Appellant had an adequate remedy at law. The Supreme Court affirmed, holding that the court of appeals correctly determined that Appellant did not lack an adequate remedy in the ordinary course of the law because he could have raised his claims by appealing his sentence. View "State ex rel. Cowell v. Croce" on Justia Law

The Supreme Court dismissed this original action in mandamus for failure to state a claim, holding that Relator was not entitled to mandamus relief.Relator, an inmate, brought this action against Respondents, nine public officials in Scioto and Franklin Counties, seeking to compel Respondents to investigate and prosecute his allegations of criminal activity and to issue arrest warrants based on the allegations. Respondents filed motions to dismiss, arguing that the complaint failed to comply with Ohio Rev. Code 2969.25's filing requirements. The Supreme Court denied the motions to dismiss because section 2969.25 did not apply. Under an independent assessment of the sufficiency of the mandamus complaint, the Court nonetheless dismissed the complaint, holding that the complaint failed to state a claim for relief in mandamus because Relator failed to allege facts that, if proved, would establish a clear legal duty to act on the part of Respondents. View "State ex rel. Evans v. Tieman" 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 correctly concluded that Appellant's petition failed to comply with the requirements of Ohio Rev. Code 2725.04(D).Appellant was imprisoned for various offenses. Appellant filed a petition for a writ of habeas corpus against the warden of the Marion Correctional Institution claiming that his maximum aggregate sentence had expired. The court of appeals granted the warden's motion to dismiss or for summary judgment, holding that Appellant had failed to attach relevant commitment papers and that his claims were barred by res judicata. View "Dailey v. Wainwright" on Justia Law