Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed Defendant’s conviction of aggravated murder and sentence of death, imposed after the case was remanded for resentencing, holding that none of Defendant’s propositions of law on appeal warranted reversal.Specifically, the Court held (1) the trial court did not err when it excluded testimony that Defendant sought to present as additional mitigating evidence in the time between the two sentencing hearings; (2) the trial court did not violate Defendant’s due process rights by refusing to empanel a new jury for the resentencing hearing; (3) trial counsel did not provide ineffective assistance at the resentencing hearing; (4) Defendant was not denied the opportunity to deny or explain evidence at the resentencing hearing; and (5) Defendant’s sentence of death was appropriate and proportional. View "State v. Goff" on Justia Law

The Supreme Court held that using a prior juvenile adjudication of delinquency for the commission of an offense that would have been felonious assault if committed by an adult as an element of the offense of having a weapon under disability, as set forth in Ohio Rev. Code 2923.13(A)(2), does not violate due process under the Ohio or United States Constitutions.Appellant was indicted on one count of having a weapon while under a disability. The alleged disability stemmed from Appellant’s prior adjudication of delinquency as a juvenile for committing a felonious assault. Appellant filed a motion to dismiss, asserting that his juvenile adjudication could not be used as a predicate for criminal conduct under section 2923.13(A)(2). The trial court denied the motion to dismiss. Appellant was subsequently convicted and sentenced. The court of appeal affirmed. The Supreme Court affirmed, holding that a previous juvenile adjudication may be an element of the weapons-under-disability offense set forth in section 2923.13(A)(2) without violating due process. View "State v. Carnes" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals that affirmed Appellant’s convictions and sentence, holding that the juvenile court’s failure to consider and apply Ohio Rev. Code 2152.021 - Ohio’s safe harbor law that benefits certain human-trafficking victims charged with juvenile delinquency - did not invalidate the court’s discretionary transfer of Appellant’s case to adult court.The juvenile court in this case found that Appellant had suffered a “very clear history of human trafficking.” Despite this finding, the juvenile court did not make any finding with respect to whether the charges related to Appellant’s victimization and did not appoint a guardian ad litem for her in the juvenile court. The court then transferred her case to adult court. Appellant pled guilty to aggravated murder and was sentenced to twenty-one years in prison. The court of appeals affirmed, holding that by pleading guilty, Appellant had waived her ability to raise the juvenile court’s error in failing to consider section 2152.021(F). The Supreme Court affirmed, holding (1) because Appellant did not object to the juvenile court’s failure to consider the applicability of section 2152.021(F), the criminal plain-error standard applied; and (2) Appellant did not carry her burden of demonstrating plain error. View "State v. Martin" on Justia Law

At issue was whether an exception in Ohio law providing that jail-time credit does not apply to the portion of a prison sentence that is imposed for a firearm specification, as applied in this case, violates equal-protection guarantees.Defendant was sentenced to an aggregate prison term that included two mandatory terms for firearm specifications. Before sentencing, Defendant filed a motion to credit the time that he had served in jail prior to sentencing toward the four years that he needed to serve for the firearm specifications. The trial court determined that the jail-time credit should be applied only to Defendant’s prison terms imposed for the underlying felonies. The court of appeals reversed, concluding that the failure to apply jail-time credit to Defendant’s firearm-specification terms would risk an equal protection violation should Defendant be granted judicial release. The Supreme Court revered, holding (1) the plain language of Ohio Rev. Code 2929.14(B)(1)(b) does not allow jail-time credit to be applied to mandatory firearm-specification sentences; and (2) there was no equal protection violation in this case. View "State v. Moore" on Justia Law

The Supreme Court granted Cuyahoga County Prosecuting Attorney Michael C. O’Malley a writ of prohibition and ordered Cuyahoga County Common Pleas Court Judge Cassandra Collier-Williams to vacate her journal entry granting intervening-respondent Kelly Foust’s renewed motion for a capital resentencing hearing before a jury, holding that Judge Collier-Williams patently and unambiguously lacked jurisdiction to empanel a jury for a resentencing hearing in this capital-murder case when Foust validly waived a jury trial.Foust filed a renewed motion for a penalty phase hearing before a jury based on Hurst v. Florida, __ U.S. __ (2016), arguing that Hurst guaranteed a capital defendant an unequivocal right to a jury determination of every fact necessary to impose a death sentence and that he was entitled to withdraw his earlier jury waiver. The judge granted Foust’s renewed motion. The Supreme Court granted O’Malley a writ of prohibition, holding that O’Malley established that Judge Collier-Williams patently and unambiguously lacked jurisdiction to invalidate Foust’s previous jury waiver and empanel a jury for his resentencing hearing. View "State ex rel. O'Malley v. Collier-Williams" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant’s petition for a writ of mandamus to compel the Ohio Parole Board to hold a parole hearing at which Appellant’s parole request would be given “meaningful consideration,” holding that Appellant did not demonstrate that the parole board failed to give his parole request meaningful consideration.On appeal, Appellant argued that the parole board did not give his parole request meaningful consideration as a result of materially false or misleading information in his parole record. The Supreme Court disagreed, holding that that Appellant failed to demonstrate that his parole record contained false or misleading information that might have adversely affected the board’s consideration of his parole request. 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 writs of mandamus and prohibition against Judge Patrick M. McGrath of the Court of Claims, holding the complaint was properly dismissed.Appellant, then an inmate, filed a negligence action against the Ohio Department of Rehabilitation and Correction. Judge McGrath dismissed the suit. The Court of Appeals reversed and remanded for further proceedings. While Appellant’s negligence action was pending on remand, Appellant filed his complaint for writs of prohibition and mandamus seeking an order prohibiting Judge McGrath from conducting proceedings on the defendant’s liability and requiring the judge to hold a damages-only hearing on Appellant’s negligence claim. The Court of Appeals dismissed the complaint. The Supreme Court affirmed, holding (1) the Court of Appeals correctly dismissed the complaint on the grounds that Appellant had misunderstood the Court of Appeals’ order to the Court of Claims, which held only that Appellant had met the liberal pleading standards required for complaints of negligence and not that Appellant had prevailed on the merits; and (2) nothing in the record suggested that Judge McGrath was refusing to comply with the Court of Appeals’ mandate, nor did the judge lack the authority to preside over a claim for relief in negligence. View "State ex rel. Evans v. McGrath" on Justia Law

The Supreme Court affirmed the court of appeals’ judgment dismissing Appellant’s complaint for a writ of procedendo against retired Judge Richard D. Reinbold Jr. and Summit County Court of Common Pleas Judge Mary Margaret Rowlands.In his action for a writ of procedendo Appellant alleged that he had never received a final, appealable sentencing order and asked the court to order Judge Reinbold and/or Judge Rowlands to issue a “proper” final sentencing entry. The court of appeals dismissed the case sua sponte because Appellant had an adequate remedy at law. The Supreme Court affirmed, holding that Appellant was not entitled to an extraordinary writ in this case. View "State ex rel. Payne v. Reinbold" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant’s complaint for a writ of procedendo against Summit County Common Pleas Court Judge Christine Croce.Appellant was convicted of multiple offenses, including two counts of aggravated murder with capital specifications. Later, a visiting judge sitting by assignment held a resentencing hearing to correct a notification regarding Appellant’s postrelease control and issued a new sentencing entry. The court of appeals concluded that the visiting judge’s corrective entry should have been labeled a nunc pro tunc entry and remanded the case for that correction. On remand, Judge Croce issued the nunc pro tunc sentencing order. Appellant then filed his petition for a writ of procedendo alleging the neither the sentencing entry nor the nunc pro tunc entry was a final appealable order and asked the court to issue a writ of procedendo to compel Judge Croce to enter a revised journal entry that would be final and appealable. The court of appeals granted Judge Croce’s motion to dismiss, concluding that a writ of procedendo was not appropriate. The Supreme Court affirmed, holding that Appellant failed to state a claim for a writ of procedendo. View "State ex rel. Williams v. Croce" on Justia Law

The Supreme Court dismissed for lack of jurisdiction this appeal from a judgment of the court of appeals that dismissed the petition for a writ of habeas corpus filed by Appellant, holding that the notice of appeal was untimely.The court of appeals dismissed the action in this case because Appellant had failed to include certain commitment papers with his petition. The court of appeals then denied Appellant’s application for reconsideration. Appellant purported to appeal both decisions to the Supreme Court. The Supreme Court dismissed the appeal for lack of jurisdiction, holding (1) Appellant’s notice of appeal was untimely; and (2) Appellant’s application for reconsideration could not cure the untimeliness of his appeal. View "State ex rel. White v. Richard" on Justia Law