Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals reversing Defendant’s conviction and discharging him from further prosecution after the trial court accepted Defendant’s plea of no contest to a charge of cruelty to animals and finding Defendant guilty but neglecting to ask for an explanation of the circumstances, holding that the Double Jeopardy Clause did not bar Defendant’s retrial.On appeal, Defendant argued that the trial court erred by failing to obtain an explanation of the circumstances before finding him guilty. The court of appeals agreed, reversed Defendant’s conviction and, reasoning that the reversal was based on insufficient evidence, concluded that jeopardy had attached and barred further proceedings against Defendant. The Supreme Court reversed, holding (1) the reversal of Defendant’s conviction was not based on insufficiency of the evidence, but, rather, on a procedural error; and (2) therefore, the double jeopardy protection did not bar Defendant’s retrial. View "Girard v. Giordano" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the trial court’s decision denying Defendant’s Motion to Vacate Judicial Sanction and reinstated the judgment of the trial court, holding that postrelease control was properly imposed.Defendant was sentenced by the common pleas court to a prison term and to post-release control. Defendant later pleaded guilty to robbery and theft. The trial court found that Defendant was on post-release control at the time he committed the offenses, terminated the post-release control, and ordered that the remainder of the post-release control be served as a prison term. Defendant moved to vacate the judicial sanction, but the trial court denied the motion. The court of appeals reversed, holding that the failure to the common pleas court sentencing entry to advise Defendant to the consequences contained within Ohio Rev. Code 2929.141(A) prohibited the sanctions from being imposed. The Supreme Court reversed based on State v. Gordon, 109 N.E.3d 1201 (Ohio 2018), and State v. Grimes, 85 N.E.3d 700 (Ohio 2017), holding that a trial court is not required to notify an offender of the penalty provisions for violating postrelease control contained in section 2929.141(A). View "State v. Johnson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus to Michael Cobb, an Ohio prisoner, holding that Cobb was not entitled to the writ.Michael Cobb filed his complaint for a writ of mandamus requesting an order compelling the Ohio Adult Parole Authority to correct five alleged inaccuracies in the records that the Ohio Parole Board relied on in denying Cobb’s request for parole and to hold a new hearing. The court of appeals denied the writ on the grounds that Cobb failed to demonstrate a substantive error that may have influenced the parole board’s consideration of parole. The Supreme Court affirmed, holding that there was not a credible allegation of error in Cobb’s parole-board file sufficient to trigger the parole board’s duty to review his file. View "State ex rel. Cobb v. Adult Parole Authority" on Justia Law

The Supreme Court vacated the trial court’s judgment - and, in turn, the court of appeals’ judgment - granting Defendant’s petition for postconviction relief and remanded this matter for further proceedings, holding that the trial court lacked subject-matter jurisdiction to grant Defendant’s petition for postconviction relief.Defendant was convicted of aggravated murder, aggravated burglary, and two counts of rape and sentenced to death. The court of appeals and Supreme Court affirmed the convictions and death sentence. This appeal concerned Defendant’s fourth postconviction petition. Defendant filed his petition in the Cuyahoga County Court of Common Pleas, challenging DNA testing done on the victim’s vagina. After holding an evidentiary hearing, the court acquitted Defendant of vaginal rape, dismissed the other rape charge, and granted Defendant a new trial on the remaining counts. The court of appeals affirmed. The Supreme Court vacated the judgment, holding that, under the circumstances presented in this case, the General Assembly has not authorized a court of common pleas to exercise jurisdiction over a petition for postconviction relief. View "State v. Apanovitch" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals denying Appellant’s complaint for a writ of mandamus to compel the Hamilton County Clerk of Courts to produce public records and granted a limited writ of mandamus as to Appellant’s third request for documents.Appellant was convicted of aggravated murder. Appellant later sent a public-records request to the clerk of courts requesting six documents pertaining to his criminal case. Because the clerk did not respond to the public records request Appellant filed a complaint for a writ of mandamus compelling production of the documents. The court of appeals granted summary judgment in favor of the clerk. The Supreme Court reversed in part and issued a limited writ of mandamus as to Appellant’s third request for documents requiring the clerk to provide responsive records or to clarify that no such records exist, holding that the record was unclear as to this request. View "State ex rel. Harris v. Preval" on Justia Law

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