Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the Court of Appeals reversing Defendant’s conviction after ruling that Defendant’s blackout defense was not an affirmative defense that must be proven by a preponderance of the evidence, holding that blackout is an affirmative defense pursuant to Ohio Rev. Code 2901.05(D)(1)(b).A jury found Defendant guilty of felonious assault. On appeal, Defendant argued that the trial court committed structural error by instructing the jury that blackout is an affirmative defense. The Court of Appeals agreed and reversed Defendant’s conviction. The Supreme Court reversed, holding (1) Defendant’s blackout defense was an affirmative defense that would allow the defendant to avoid liability even if the state produced sufficient evidence to support a conviction; (2) the requirement that the state prove that the defendant acted voluntarily is not an additional element or burden on the state; and (3) the trial court properly instructed the jury that the state had the burden of proving each element of the offense beyond a reasonable doubt, and the trial court did not shift to Defendant the state’s burden to prove an essential element of the offense charged. View "State v. Ireland" 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 Ross County Common Pleas Court Judge Scott Nusbaum, holding that Appellant was not entitled to relief in mandamus or prohibition.Appellant, an inmate, filed a petition for a writ of habeas corpus in the court of common pleas. Judge Nusbaum dismissed the petition based on res judicata and for failure to state a claim cognizable in habeas. Appellant later commenced this action against Judge Nusbaum alleging that the judge lacked jurisdiction over the habeas petition. The Court of Appeals granted Judge Nusbaum’s motion to dismiss. The Supreme Court affirmed, holding that Appellant failed to demonstrate that the judge lacked jurisdiction over the habeas petition. View "State ex rel. White v. Nusbaum" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant’s complaint for a writ of prohibition to prevent Judge Richard L. Collins Jr. from proceeding with a hearing to determine whether Appellant should be designated a sexual predator pursuant to Megan’s Law, holding that Appellant failed to show entitlement to a writ of prohibition.In this action, Appellant argued that since the General Assembly enacted the Adam Walsh Act (AWA), Megan’s Law has been repealed and could not be applied to him. The Supreme Court disagreed, holding (1) Judge Collins did not patently and unambiguously lack jurisdiction to conduct a sexual-predator adjudication hearing relating to Appellant’s 1986 convictions for kidnapping and involuntary manslaughter because Megan’s Law continues to apply to offenders convicted before 2008; and (2) Appellant had an adequate remedy in the ordinary course of law to challenge Judge Collins’s exercise of jurisdiction. View "State ex rel. Grant v. Collins" on Justia Law

The Supreme court affirmed the judgment of the court of appeals denying Appellant’s motions to issue a show-cause order and to hold Appellees, Ohio Adult Parole Authority and the Chair of the Ohio Parole Board, in contempt for failing to conduct a new parole hearing, holding that there was no basis for ordering Appellees to take action or find them in contempt.Appellant, then an inmate, filed an original action seeking a writ of mandamus, alleging that he had been denied meaningful parole consideration because Appellees had relied on incorrect information in his parole record. The court of appeals denied the writ. The Supreme Court reversed, ordering Appellees to correct any information on Appellant’s parole record that was incorrect. Appellant later filed a motion for contempt and a motion for a show-cause order. The court of appeals denied the motions. The Supreme Court affirmed, holding that Appellees complied with this Court’s original order, and therefore, there was no basis for ordering them to take additional action, much less a finding of contempt. View "State ex rel. Keith v. Department of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant’s complaint for a writ of mandamus against the Lake County Common Pleas Court, holding that the court of appeals correctly dismissed the complaint.Appellant was convicted in the Lake County Common Pleas Court on several criminal counts. The court of appeals affirmed. Thereafter, Appellant brought this action for a writ of mandamus against the Lake County Common Pleas Court, raising numerous objections to his convictions and sentences but requesting no specific mandamus relief. The court of appeals dismissed the complaint for failure to state a claim in mandamus. The Supreme Court affirmed, holding that Appellant was not entitled to a writ of mandamus. View "State ex rel. Sands v. Court of Common Pleas" on Justia Law

The Supreme Court denied Respondent’s motion to dismiss this original action in mandamus brought by Relator and issued an alternative writ, holding that Respondent was not entitled to have the complaint dismissed.Relator, an inmate at the Southern Ohio Correctional Facility, alleged that he submitted a public-records request to Respondent, the public-records custodian for the facility but never received the requested documents. Relator filed a complaint for a writ of mandamus asking the Supreme Court to compel Respondent to provide him the documents. Respondent moved to dismiss the complaint based on Relator’s failure to comply with the filing requirements set forth in Ohio Rev. Code 2969.25. The Supreme Court held that section 2969.25 does not apply to this matter, and because it does not apply, Respondent’s motion to dismiss is denied and Relator is entitled to an alternative writ. View "State ex rel. Martin v. Greene" on Justia Law

The Supreme Court affirmed the district court’s dismissal of Appellant’s petition for a writ of habeas corpus, holding that the court of appeals correctly determined that Appellant’s petition was defective on its face.In 2009, Appellant pleaded guilty to multiple theft offenses. In 2010, Appellant pleaded guilty to four charges in two separate cases. In 2017, Appellant filed a petition fro a writ of habeas corpus alleging that he was entitled to immediate release because he had served his sentences. The court of appeals dismissed the petition for number of procedural and substantive reasons, including Appellant’s failure to attach all his commitment papers in violation of Ohio Rev. Code 2725.04(D). The Supreme Court affirmed, holding that Appellant’s petition failed to comply with section 2725.04(D). View "State ex rel. Cannon v. Mohr" on Justia Law

The Supreme Court affirmed the decision of the Court of Appeals denying Appellant’s complaint for a writ of procedendo against Cuyahoga County Common Pleas Court Judge Michael Donnelly, holding that Appellant was not entitled to the relief he sought.In his complaint for a writ of procedendo, Appellant alleged that his postconviction petition had been pending before Judge Donnelly for more than six months without decision. Thereafter, Judge Donnelly denied Appellant’s postconviction petition. The Court of Appeal denied the writ on the ground of mootness. The Supreme Court affirmed, holding that the Court of Appeals correctly determined that Appellant’s complaint failed to state a claim in procedendo. View "Thompson v. Donnelly" on Justia Law

The Supreme Court affirmed the judgment of the trial court denying Appellant’s second-degree application for DNA testing, holding that Appellant was not entitled to the relief he sought.Appellant was convicted of two counts of aggravated murder and sentenced to death. This appeal was taken from the trial court’s denial of Appellant’s second-degree application for DNA testing. On appeal, Appellant presented two propositions of law for the Supreme Court’s consideration. The Court denied relief, holding (1) this Court lacked jurisdiction to consider Appellant’s first proposition of law; and (2) Appellant failed to show any of the evidence he sought to have tested could be outcome determinative. View "State v. Bonnell" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant’s petition for a writ of mandamus against Appellee, Hamilton County Common Pleas Court Judge Ethan Cooper, holding that Appellant had - and had used - an adequate remedy in the ordinary course of the law.Appellant’s mandamus claim challenged the credibility of the evidence on which his aggravated-robbery conviction was based. On direct appeal, however, Appellant challenged his conviction on insufficient-evidence and manifest-weight grounds. The Supreme Court, therefore, held that Appellant was not entitled to a writ of mandamus and that res judicata barred his claims concerning the insufficiency of the evidence supporting his conviction. View "State ex rel. Simpson v. Cooper" on Justia Law