Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals vacating Defendant's convictions for violation of Defendant's right to a speedy trial, holding that speedy-trial time is tolled when a defendant's request for a continuance is made in open court and on the record or the reasons for the request are evidence from the record.The trial court denied Defendant's motion to dismiss the misdemeanor charges against her for violation of her right to a speedy trial, concluding that, after factoring in the periods of delay attributable to Defendant, ninety days had not elapsed from the date of her arrest to the date she filed her motion to dismiss. The court of appeals reversed and vacated Defendant's convictions, holding that the continuances in this case, while entered on behalf of Defendant, must be charged against the State because the trial court's journal entries either failed to identify Defendant as the requesting party or failed to explain the precise reasons for the delay. The Supreme Court reversed, holding that speedy-trial time is not chargeable to the State when the reasons for the defendant's request for a continuance are evident from the record, regardless of whether or not the trial court specifically journalizes those reasons on its docket sheet. View "State v. Martin" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Appellant's Civ.R. 60(B) motion for relief from judgment and denied the five motions that Appellant filed in this case, holding that the court of appeals did not abuse its discretion in denying Appellant's motion.Appellant filed a complaint for a writ of mandamus arguing that he was entitled to be released from prison. The court of appeals dismissed the complaint, concluding that Appellant was not entitled to a writ of mandamus. Appellant then filed a Civ.R. 60(B) motion seeking relief from the court of appeals' judgment. The court of appeals denied the motion. Appellant later moved for relief from judgment on the same grounds previously asserted. The court of appeals denied the motion on res judicata grounds. The Supreme Court affirmed after denying the Ohio Department of Rehabilitation and Correction's motion to dismiss, holding (1) the court of appeals correctly denied Appellant's second Civ.R. 60(B) motion on the basis of res judicata; and (2) none of Appellant's pending motions had merit. View "State ex rel. Richard v. Chambers-Smith" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus and/or procedendo to compel Franklin County Court of Common Pleas Judge William H. Woods to issue a corrected sentencing entry, holding that Appellant had an adequate remedy in the ordinary course of the law by way of appeal.In 2006, the common pleas court issued an entry resentencing Defendant for his 2005 convictions for murder and felonious assault. In 2017, Defendant filed in the court of appeals a complaint for a writ of mandamus and/or procedendo arguing that he was entitled to a new sentencing entry that complied with Ohio Rev. Code 2505.02 and Crim.R. 32(C). The court of appeals dismissed the complaint for failure to state a claim. The Supreme Court affirmed, holding that Appellant's action was barred because he had an adequate remedy at law. View "State ex rel. White v. Woods" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus to compel Appellee, Judge Megan E. Shanahan of the Hamilton County Court of Common Pleas, to provide public records relating to his incarceration, holding that Appellant improperly sought records under the Public Records Act rather than the Rules of Superintendence.Appellant was convicted of aggravated burglary, abduction, and rape. Appellant later filed motions seeking the inspection and release of public records relating to his case. Judge Shanahan denied the motions, noting that Appellant could access all publicly available records through the clerk of courts. Appellant then filed his petition for a writ of mandamus. The court of appeals dismissed the writ, concluding that since Appellant was incarcerated, a sentencing court must first determine that the court records were necessary to support a justiciable claim. The Supreme Court affirmed but on different grounds, holding that the court of appeals erred in applying the Ohio Public Records Act, Ohio Rev. Code 149.43, to Appellant's records request and that the court of appeals correctly dismissed the case. View "State ex rel. Husband v. Shanahan" 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 Warden Brandeshawn Harris, holding that Appellant's underlying claims were not cognizable in habeas corpus.Appellant filed in the court of appeals a petition for a writ of habeas corpus arguing that that, as a result of several errors, he had already served his total sentence. The court of appeals granted the warden's motion to dismiss for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding that Appellant's claims were not cognizable in habeas corpus. View "Rock v. Harris" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the trial court's denial of Appellee's motion to withdraw a guilty plea based on his claim of ineffective assistance of counsel, holding that the trial court erred in denying Appellee's motion without considering the two-prong test for ineffective assistance of counsel established in Strickland v. Washington, 466 U.S. 668 (1984) and applied in the immigration context but that the court of appeals' remand order for a full evidentiary hearing was premature.In his motion, Appellee claimed ineffective assistance of counsel because his attorney had failed to advise him of the immigration consequences of his pleas. The trial court denied the motion. The court of appeals reversed and remanded to the trial court to conduct a hearing, concluding that the trial court erred by denying the motion without deciding whether counsel properly advised Appellee. The Supreme Court affirmed and remanded the matter to the trial court for application of the proper standard, holding that the trial court erred in denying Appellee's motion without considering the two-prong test for ineffective assistance of counsel established in Strickland and applied in Padilla v. Kentucky, 559 U.S. 356 (2010). View "State v. Romero" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's petition for a writ of habeas corpus, holding that Appellant did not show that he was entitled to the writ.In his habeas corpus petition, Appellant, an inmate, argued that the Bureau of Sentence Computation miscalculated his prison term and that his jail-time credit was improperly calculated. The court of appeals dismissed the petition. The Supreme Court affirmed, holding (1) Appellant's prison term was properly calculated; and (2) Appellant's claim that he was entitled to additional jail-time credit was not cognizable in habeas corpus actions. View "State ex rel. Shafer v. Wainwright" on Justia Law

The Supreme Court denied as moot Relator's complaint seeking a writ of mandamus against Larry Greene, the administrative assistant for the warden of the Southern Ohio Correctional Facility, to compel the production of public records, holding that Relator was not entitled to mandamus because he received the documents that he requested.After Relator, an inmate, submitted a public-records request he filed a complaint for writ of mandamus against Greene. Eight days later, Relator was provided with copies of the requested records. Greene filed a motion to dismiss on the grounds that Relator filed to attach certain documents to the complaint. Three months late, Relator filed a motion asking the Court to consider the affidavit and exhibits attached to his complaint as substantive evidence. The Supreme Court (1) denied the writ of mandamus as moot; (2) denied Relator's demand for statutory damages and court costs on the merits; and (3) denied Relator's motion to have the attachments to his complaint accepted as service as moot. View "State ex rel. Martin v. Greene" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition against an unnamed judge of the Summit County Court of Common Pleas, holding that Appellant's complaint failed to state a claim and was correctly dismissed.Appellant was found guilty of aggravated murder. Because he was charged under Ohio Rev. Code 2903.01(B), which requires that the death occurred during the commission of an underlying felony, and he was acquitted of the alleged underlying felony, Appellant alleged in his complaint that the law required him to be acquitted of aggravated murder. The court of appeals dismissed Appellant's complaint for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding (1) Appellant's mandamus complaint failed to state a claim and was correctly dismissed; and (2) Appellant failed to state a claim for relief in prohibition. View "State ex rel. Zander v. Judge of Summit County Common Pleas Court" on Justia Law

In this original action brought by Cuyahoga County Prosecuting Attorney Michael C. O'Malley seeking a writ of prohibition to prevent Cuyahoga County Court of Common Pleas Judge Michael J. Russo from exercising jurisdiction over a wrongful imprisonment claim filed by Joe D'Ambrosio and a writ of procedendo to compel Judge Russo to terminate D'Ambrosio's litigation, the Supreme Court granted Judge Russo's motion for judgment on the pleadings, holding that O'Malley was not entitled to either writ.D'Ambrosio commenced a wrongful imprisonment action in the common pleas court under Ohio Rev. Code 2743.48. The trial court granted summary judgment for D'Ambrosio. The Supreme Court reversed. Thereafter, D'Ambrosio filed a new complaint in common pleas court again asserting a wrongful imprisonment claim. The State moved for judgment on the pleadings, arguing that the mandate rule and the doctrines of law of the case and res judicata barred the action. The trial court denied the State's motion. The Supreme Court granted Judge Russo's motion for judgment on the pleadings, holding that O'Malley had not alleged facts supporting the issuance of a writ of prohibition or a writ of procedendo. View "State ex rel. O'Malley v. Russo" on Justia Law