Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus to compel the court of common pleas judge to resentence him, holding that Appellant had an adequate remedy at law by way of appeal.Appellant was convicted of the rape of and gross sexual imposition on a child less than thirteen years of age. Appellant later filed a complaint for a writ of mandamus arguing that his sentence was void because the trial court failed properly to notify him of his post release control and abused its discretion in sentencing him to a definite term of life imprisonment. The court of appeals dismissed the complaint, concluding that res judicata barred Appellant's arguments. The Supreme Court affirmed, holding (1) the court of appeals erred when it dismissed Appellant's mandamus claim on res judicata grounds; but (2) Appellant had an adequate remedy of law by way of appeal, and therefore, Appellant was not entitled to mandamus relief. View "State ex rel. Green v. Wetzel" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the trial court overruling Defendant's motion to suppress evidence relating to a traffic stop, holding that the arresting officer had reasonable suspicion to make an investigatory stop.In affirming the trial court, the court of appeals determined that the discrepancy between the color in the vehicle's registration and the actual color of the vehicle was sufficient to raise the officer's suspicion to that vehicle was either stolen or that the license plate had been taken from another vehicle. The Supreme Court affirmed, holding that when a police officer encounters a vehicle that is painted a different color from the color listed in the vehicle registration records and the officer believes that the vehicle or its license plates may be stolen, the officer has a reasonable, articulable suspicion of criminal activity and is authorized to perform an investigative traffic stop. View "State v. Hawkins" on Justia Law

The Supreme Court granted Appellant's motion for reconsideration and vacated its decision in State v. Braden, __ N.E.3d __ (Ohio 2018) (Braden I), holding that Ohio Rev. Code 2947.23(C) grants a sentencing court jurisdiction to waive, suspend, or modify the payment of the costs of prosecution imposed prior to the statute's effective date.In Braden I, the Supreme Court held that the General Assembly did not expressly make section 2947.23(C) retroactive and that, with respect to costs imposed before the statute's enactment, the trial court lacked jurisdiction to reconsider its own final order. The Court then granted Appellant's motion for reconsideration and vacated its decision in Braden I, holding that neither section 2947.23(C) nor this Court's precedent precludes trial courts from waiving, suspending, or modifying court costs imposed before the effective date of section 2947.23(C). View "State v. Braden" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting the writ of mandamus sought by Appellant concerning certain public records Appellant had requested but denied the writ concerning others, holding that because Appellant did not comply with Ohio Rev. Code 149.43(B)(8) Cleveland Police Forensic Laboratory (CPFL) had no clear legal duty to produce the records identified in the first part of Appellant's request.The court of appeals denied the writ as to the first part of Appellant's request, determining that Appellant had not obtained court approval before requesting public records concerning a criminal investigation or prosecution, as he was required to do under Ohio Rev. Code 149.43(B)(8). The court noted that section 149.43(B) did not apply to the second part of Appellant's request, which did not seek records concerning a criminal investigation or prosecution. The Supreme Court affirmed, holding that because Appellant did not obtain court approval as required by section 149.43(B)(8), the court of appeals properly denied the first part of his request. View "State ex rel. Ellis v. Cleveland Police Forensic Laboratory" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's request for a writ of mandamus and granting summary judgment in favor of Appellee, Cuyahoga County Court of Common Pleas Judge Pamela Barker, holding that Appellant's three propositions of law lacked merit.In 2014, Appellant was found guilty of aggravated murder and other crimes. Judge Barker sentenced Appellant. In 2018, Judge Barker granted in part Appellant's motion to correct a facially illegal sentence and entered a nunc pro tunc entry clarifying that the firearm specifications had been merged for sentencing. Thereafter, Appellant filed a complaint in mandamus seeking to compel Judge Barker to vacate both he 2014 sentencing order and the 2018 nunc pro tunc entry and to repentance him, claiming that certain errors rendered the 2014 sentencing enter void. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant failed to establish that she was entitled to a writ of mandamus. View "State ex rel. Rodriguez v. Barker" on Justia Law

The Supreme Court affirmed the judgments in these consolidated appeals, holding that the court of appeals properly dismissed Appellant's complaint for a writ of habeas corpus as well as Appellant's complaint for a writ of mandamus.Appellant was convicted of two counts of rape and kidnapping. Appellant filed a petition for a writ of habeas corpus arguing that he was entitled to habeas relief on the rape sentences because he had completed the maximum term for those convictions. The court of appeals dismissed the petition for failure to state a claim. Appellant also filed a petition for a writ of mandamus claiming that his kidnapping sentence exceeded date statutory maximum and that his sentence therefore should be modified. The court of appeals dismissed the petition for failure to state a claim. The Supreme Court affirmed, holding that the court of appeals (1) properly dismissed Appellant's petition for a writ of habeas corpus, and (2) correctly dismissed Appellant's mandamus action for failure to state a claim. View "State ex rel. Norris v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting summary judgment in favor of Appellees and denying Appellant's petition for a writ of mandamus, holding that Appellant failed to establish that he was entitled to a writ of mandamus.Appellant was found guilty of engaging in a pattern of corrupt activity and other offenses. Appellant later filed his petition for a writ of mandamus claiming that the indictment had failed to place him on notice of the predicate offenses underlying the charges and failed to charge essential elements of the underlying predicate offenses. The court of appeals denied the petition, holding 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 summary judgment motion based on res judicata, the court properly ruled in favor of Appellees because relief in mandamus is unavailable to challenge a defective indictment. View "State ex rel. Sands v. Culotta" on Justia Law

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