Justia Ohio Supreme Court Opinion Summaries

In this mandamus action, the Supreme Court affirmed the judgment of the court of appeals denying Appellant’s motion to waive court costs and denied Appellant’s motion to appoint counsel.Appellant filed a complaint for a writ of mandamus to compel the Department of Rehabilitation and Correction to review a correction officer’s alleged deployment of a chemical spray in Appellant’s face that caused severe burns. Appellant also sought a waiver of the prepayment of filing fees. The court of appeals dismissed the case sua sponte. Appellant then filed a motion asking the court of appeals to waive all court costs and filing fees on the ground that he had previously been declared indigent. The court denied the motion to waive costs. Appellant appealed the denial of his motion to waive costs and moved for appointment of counsel. The Supreme Court denied the motion to appoint counsel and affirmed the denial of Appellant’s motion to waive costs, holding that Appellant’s argument was raised for the first time on appeal and was therefore beyond the scope of the appeal. View "State ex rel. Russell v. Department of Rehabilitation and Correction" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant’s complaint for a writ of procedendo against Franklin County Common Pleas Court Judge Jenifer French, holding that the intermediate appellate court properly dismissed Appellant’s complaint for failure to attach the statement of inmate account required by Ohio Rev. Code 2969.25(C).In his complaint, Appellant alleged that he had filed a petition for postconviction relief and that Judge French had not yet ruled on the petition, as required by Ohio R. Crim. P. 35(C). The court of appeals dismissed the complaint on the grounds that Appellant had failed to comply with the requirements of Ohio Rev. Code 2969.25(C). The Supreme Court affirmed, holding that Appellant’s noncompliance with section 2969.25(C) required dismissal of his complaint. View "State ex rel. Neil v. French" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant’s complaint for a writ of mandamus against Erie County Common Pleas Court Judge Roger E. Binette and denied Appellant’s motions for judgment on the pleadings and for an order to the clerk of courts, as well as Binette’s motion to dismiss.Appellant filed this original action for a writ of mandamus to compel Judge Binette to vacate his sentence and conduct a new sentencing hearing on the grounds that his sentence was void. The court of appeals sua sponte dismissed the complaint as frivolous. The Supreme Court denied the motions filed by Appellant and Binette and affirmed the judgment, holding that the court of appeals properly denied Appellant’s complaint. View "State ex rel. Hunter v. Binette" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant’s request for writs of mandamus and/or procedendo against Cuyahoga County Court of Common Pleas Judge Hollie L. Gallagher and Cuyahoga County Clerk of Courts Nailah Byrd and denied the motions filed by Appellant during the pendency of this case.Appellant filed an original action in the court of appeals against Judge Gallagher alleging that his 1995 sentencing entry was void for several reasons. Appellant sought writs of mandamus and/or procedendo to compel Judge Gallagher to conduct a de novo resentencing and issue a new final, appealable order, and to compel Byrd to journalize the new sentencing entry once it was created. The court of appeals granted summary judgment in favor of Judge Gallagher and Byrd. The Supreme Court affirmed, holding that Appellant failed to demonstrate that he was entitled to relief. View "State ex rel. Arnold v. Gallagher" on Justia Law

The Supreme Court affirmed the court of appeals’ dismissal of Appellant’s petition for a writ of habeas corpus that he filed against LaShann Eppinger, warden of the Grafton Correctional Institution, where Appellant was incarcerated, holding that the court of appeals correctly dismissed the petition for failure to state a claim.In his petition, Appellant argued that he was entitled to immediate release because his aggregate minimum sentence for his 1992 convictions exceeded the allowable limit under former Ohio Rev. Code 2929.41(E). The court of appeals granted Eppinger’s motion to dismiss for failure to state a claim. The Supreme Court affirmed, holding that because Appellant had not completed his aggregate maximum sentence, the court of appeals correctly dismissed his petition for failure to state a claim. View "State ex rel. Fuller v. Eppinger" on Justia Law

The Supreme Court affirmed the court of appeals’ dismissal of Appellant’s petition for a writ of habeas corpus filed against the warden of the correctional facility where Appellant was incarcerated.Appellant claimed that he was entitled to a writ of habeas corpus because he had served more than sixteen years’ imprisonment on a fifteen-year prison sentence. Specifically, Appellant claimed that the Department of Rehabilitation and Correction unilaterally extended his sentence by running his two prison terms consecutively without judicial sanction. The Supreme Court affirmed the denial of the petition for a writ of habeas corpus, holding that Appellant’s sentences ran consecutively by operation of statute, and therefore, the Department did not change Appellant’s sentence or aggregate his sentences on its own initiative. View "State ex rel. Smith v. Schweitzer" on Justia Law

A social worker’s statutory duty to cooperate and share information with law enforcement regarding a child abuse investigation does not render the social worker an agent of law enforcement for purposes of the Fifth and Sixth Amendments to the United States Constitution if the social worker interviews an alleged perpetrator unless the evidence demonstrates that the social worker acted at the direction or under the control of law enforcement.Defendant was convicted of kidnapping, gross sexual imposition, and two counts of rape. Social worker and child advocate Holly Mack interviewed Defendant after he was arrested. During trial, defense counsel objected to Mack’s testimony about the statements Jackson had made to her because she questioned him “as an agent of the State and law enforcement” and failed to notify Defendant of his Miranda rights. The trial court allowed Mack to testify. The appellate court reversed the convictions, holding that Mack acted as an agent of law enforcement when she interrogated Defendant. The Supreme Court reversed, holding that no evidence indicated that Mack acted at the direction or under the control of law enforcement when she interviewed Jackson. View "State v. Jackson" on Justia Law

The Supreme Court granted a writ to Relator, who filed a complaint for a writ of mandamus to compel the common pleas court to enforce its 2013 order sealing the record in a criminal case against Relator and to rule on his 2017 motion to reseal the record.Relator alleged that after the records at issue were sealed the court of appeals made his appellate records public again. Relator then filed an emergency motion for an order resealing his records. When no action was taken to enforce the order to seal or ruling on the motion to reseal Relator filed his complaint for a writ of mandamus. The common pleas court filed a motion to dismiss the complaint. The Supreme Court denied the motion to dismiss, sue sponte converted Relator’s complaint to a request for a writ of procedendo, granted a writ ordering the common pleas court to rule on Relator’s motion to reseal, and granted Relator’s motion to seal the pleadings filed in this original action. View "State ex rel. Doe v. Gallia County Court of Common Pleas" on Justia Law

The Supreme Court affirmed the judgments of the two courts of appeals dismissing Appellant’s petition for a writ of habeas corpus and Appellant’s petition for writs of prohibition and mandamus.Appellant was convicted in two separate common pleas cases, one involving the murder and robbery of Christine Kozak (the Kozak case) and the other case involving the robberies of David Sotka and the Lawson Milk Company (the Sotka case). In both of his petitions, Appellant challenged the jurisdiction of the general division of the common pleas court in both the Kozak case and the Sotka case. Both petitions alleged that there was an allegedly defective transfer from the juvenile division. The Supreme Court held (1) the court of appeals correctly dismissed Appellant’s habeas petition for failure to state a claim cognizable in habeas corpus; and (2) Appellant had an adequate remedy by way of appeal to challenge the validity of the bindover, and therefore, Appellant’s request for writs of prohibition and mandamus were properly dismissed. View "Johnson v. Sloan" on Justia Law

The Supreme Court granted the writ of habeas corpus sought by Tyrone Oliver and commanded Oliver’s immediate release from incarceration.In 1993, Oliver was sentenced to an indeterminate prison sentence of eight to twenty-five years for involuntary manslaughter. The Bureau of Sentence Computation calculated his maximum-sentence release date as January 9, 2018. Oliver received parole release in July 2003. In February 2005 he pleaded guilty to a domestic violence charge and received a two year sentence. On January 26, 2018, Oliver filed this petition for writ of habeas corpus, arguing that he was entitled to immediate release. The Supreme Court agreed, holding that Oliver’s 2005 sentence for domestic violence was to be served concurrently with, not consecutively to, his 1993 sentence for involuntary manslaughter, and therefore, Oliver had served his maximum sentence and was entitled to immediate release. View "State ex rel. Oliver v. Turner" on Justia Law