Justia Ohio Supreme Court Opinion Summaries

Appellant, an inmate who was serving sentences imposed for his convictions for a variety of offenses, filed an original action in the court of appeals seeking monetary damages from the Madison County Court of Common Pleas, arguing that as a result of the sentence computation of the Bureau of Sentence Computation in the Ohio Department of Rehabilitation and Correction, he was serving for a second time one of the sentences imposed on him by the Madison County Court of Common Pleas, and therefore, he was entitled to damages for false imprisonment. The court of appeals dismissed the action. The Supreme Court affirmed, holding that the State of Ohio, not the common pleas court, was the party that should have been named in this action. View "Johnson v. Madison County Court of Common Pleas" on Justia Law

The Court of Appeals erred on double jeopardy grounds in reversing the trial court’s decision to grant Appellants’ motions to dismiss an indictment that charged them with ethnic intimidation.Appellants filed their motions to dismiss the indictments brought against them in the Scioto County Court of Common Pleas because they had already been convicted in municipal court for aggravated menacing, which is the predicate offense for the charges of ethnic intimidation that were brought against them in the dismissed indictment. The Supreme Court agreed with the decision of the trial court, holding that, for double-jeopardy purposes, Appellants’ aggravated-menacing convictions were the same offenses as those charged in the dismissed indictment. View "State v. Mutter" on Justia Law

To validly impose postrelease control when the trial court orally provides all the required advisements at the sentencing hearing, the sentencing entry must contain certain required information.In 2011, the court of common pleas imposed postrelease control on Defendant as part of his sentence of convictions for robbery and vandalism. While Defendant was under postrelease control, he pled guilty to unlawful sexual conduct with a minor. The trial court sentenced Defendant to a one-year prison term and imposed a judicial-sanction sentence converting the remainder of the postrelease-control term imposed for his 2011 conviction into prison time. After Defendant completed his prison term for unlawful sexual conduct with a minor, he moved the trial court to vacate his judicial-sanction sentence and order his release from prison, arguing that the court did not validly impose postrelease control when it sentenced him for his 2011 convictions. The trial court denied the motion. The court of appeals reversed. The Supreme Court reversed and reinstated the trial court’s judgment, holding that the sentencing entry in this case included all of the required information. View "State v. Grimes" on Justia Law

In State v. Aalim, __ N.E.3d __ (Aalim I), the Supreme Court declared that the Ohio Constitution requires that a juvenile who is subject to mandatory bindover receive an amenability hearing. Implicit in this holding was the conclusion that a juvenile-division judge has discretion in deciding whether to transfer to adult court a juvenile in a case where the juvenile is sixteen or seventeen years old and there is probable cause to believe that the juvenile committed an offense outlined in Ohio Rev. Code 2152.10(A)(2)(b). The Supreme Court then granted the State’s motion for reconsideration, holding that the decision in Aalim I usurped the General Assembly’s exclusive constitutional authority to define the jurisdiction of the courts of common pleas by impermissibly allowing a juvenile division judge discretion to veto the legislature’s grant of jurisdiction to the general division of a court of common pleas over a limited class of juvenile offenders. The court further held that the mandatory bindover of certain juvenile to adult court under Ohio Rev. Code 2152.10(A)(2)(b) and 2152.12(A)(1)(b) does not violate the due course of law clause or the equal protection clause of the Ohio Constitution or the analogous provisions of the Fourteenth Amendment to the United States Constitution. View "State v. Aalim" on Justia Law

After review of Defendant’s first appeal, the Supreme Court affirmed Defendant’s convictions for aggravated murder, aggravated burglary, and aggravated robbery but vacated Defendant’s death sentence. On remand, the trial court again imposed the death sentence. On the second appeal, the Supreme Court again vacated the death sentence on the ground that the trial court had failed to consider Defendant’s allocution. A different judge presided over the third resentencing and again imposed capital punishment. The Supreme Court affirmed, holding that none of Defendant’s four propositions of law warranted relief and that the death penalty in this case was appropriate and proportionate. View "State v. Roberts" on Justia Law

At issue was whether the court of appeals erred in affirming the judgment of the county court of common pleas suppressing evidence seized during the warrantless search of an unattended book bag conducted by a school employee and the school principal. The Supreme Court reversed, holding (1) the school’s protocol requiring searches of unattended book bags to determine ownership and to ensure the safety of its contents furthers a compelling governmental interest in protecting public school students from physical harm; and (2) the school employees’ search of the unattended book bag belonging to Defendant was limited to fulfilling the purposes of the school’s search protocol and was reasonable under the Fourth Amendment. View "State v. Polk" on Justia Law

In 2007, Appellant was charged in Warren County, Ohio with two drug-related felony offenses. Appellant fled the jurisdiction before trial and was later imprisoned in Pennsylvania for federal drug convictions. In 2012, Appellant was extradited to Warren County. Appellant filed a pretrial motion to dismiss the indictment, alleging a violation of Article IV(d) of the Interstate Agreement on Detainers and, alternatively, that he was extradited to Ohio from Pennsylvania without a hearing. The trial court denied the motion to dismiss. Appellant was convicted of the felony charges and sentenced to six years’ incarceration. Appellant then filed a petition for a writ of habeas corpus, alleging that Ohio lacked jurisdiction over him because he was returned to the state pursuant to a defective extradition request. The court of appeals dismissed the motion for failure to state a claim. The Supreme Court affirmed, as “[a] claim of illegal extradition does not state a claim in habeas corpus and will not void [a] conviction.” View "State ex rel. Thomas v. Richard" on Justia Law

Defendant was charged with burglary. Before Defendant’s trial was to begin, the court confirmed that Defendant had been offered and rejected a plea offer. After a jury trial, Defendant was found guilty. Following a sentencing hearing, the court imposed a six-year term of imprisonment. Defendant appealed, arguing that the trial court vindictively imposed a sentence in retaliation for the exercise of his right to a jury trial in violation of his due process rights. The court of appeals affirmed. The Supreme Court affirmed, holding (1) there is no presumption of vindictiveness when, after trial, a court sentences a defendant to a longer term than was offered by the state in plea negotiations; (2) an appellate court may reverse a sentence for vindictiveness only if, upon its examination of the entire record, it clearly and convincingly finds the sentence was based on actual vindictiveness; and (3) applying this standard, the trial court did not vindictively sentence Defendant. View "State v. Rahab" on Justia Law

The Cuyahoga County Grand Jury indicted five individuals with two misdemeanor counts of dereliction of duty. Thereafter, the city of East Cleveland filed an identical dereliction-of-duty charge against each of the defendants in the East Cleveland Municipal Court. The defendants filed a complaint requesting a writ of prohibition, seeking to prohibit Judge William L. Dawson of the municipal court from exercising jurisdiction over the identical dereliction-of-duty charges against each of the defendants. Thereafter, the county prosecutor moved to dismiss the indictments pending in the common pleas court. The common pleas court found that the duplicate charges filed in the municipal court constituted good cause for dismissal. The defendants amended their complaint in prohibition arguing that Judge Dawson and the municipal court lacked jurisdiction over their cases, that the common pleas court inappropriate dismissed the charges previously filed in that court, and that they could not appeal from those dismissals. The court of appeals granted the requested writ. The Supreme Court reversed, holding that Judge Dawson did not patently and unambiguously lack jurisdiction to consider the indictments filed against the defendants in the municipal court and that the defendants had an adequate remedy at law in the form of appeal. View "State ex rel. Dailey v. Dawson" on Justia Law

Appellant filed a petition for a writ of mandamus seeking an order compelling Appellee, a Court of Common Pleas of Hamilton county judge, to vacate his sentence as void and to resentencing him “according to the verdict returned by the jury.” The court of appeals dismissed Appellant’s petition for a writ of mandamus. Appellant appealed and also filed a motion for reversal of judgment under S. Ct. Prac. R. 16.07(B) claiming that he was entitled to judgment in his favor because the judge failed to file a brief in this appeal. The Supreme Court affirmed and denied Appellant’s motion, holding (1) the court of appeals correctly dismissed Appellant’s petition for a writ of mandamus; and (2) Appellant’s brief did not reasonably appear to sustain reversal. View "State ex rel. Bradford v. Dinkelacker" on Justia Law