Justia Ohio Supreme Court Opinion Summaries

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

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