Justia Ohio Supreme Court Opinion Summaries

During a bar fight, Defendant knowingly killed Antwon Shannon. After a jury trial, Defendant was convicted of aggravated murder and felony murder. Defendant appealed, arguing that his aggravated murder conviction was not supported by sufficient evidence of prior calculation and design. The court of appeals agreed and reversed the conviction for aggravated murder but upheld the felony murder conviction. The court then remanded the cause for resentencing. The Supreme Court affirmed, holding (1) the evidence did not show that the killing was done with prior calculation and design as required to sustain a conviction for aggravated murder; and (2) Defendant was properly convicted of felony murder. View "State v. Walker" on Justia Law

After a jury trial, Defendant was found guilty of three counts of aggravated robbery, three counts of rape, and other offenses. Defendant was fifteen years old at the time he committed the crimes. The trial court sentenced Defendant to the maximum prison term for each count. The sentence totaled 141 years in prison. At issue before the Supreme Court in this appeal was whether, pursuant to Graham v. Florida, a term-of-years prison sentence that exceeds a defendant’s life expectancy violates the Eighth Amendment’s prohibition against cruel and unusual punishments when it is imposed on a juvenile nonhomicide offender. The Supreme Court answered this question in the affirmative and remanded the cause to the trial court for resentencing, holding (1) Graham’s categorical prohibition of sentences of life imprisonment without the possibility of parole for juveniles who commit nonhomicide crimes applies to juvenile nonhomicide offenders who are sentenced to term-of-years sentences that exceed their life expectancies; and (2) therefore, Defendant’s 112-year sentence violates the Eighth Amendment. View "State v. Moore" on Justia Law

A complaint was filed in the juvenile court alleging that Appellant engaged in conduct that would be considered aggravated robbery if committed by an adult. Appellant was sixteen years old at the time of the alleged offense. The State filed a motion to transfer Appellant to the general division of the common pleas court to be tried as an adult pursuant to Ohio Rev. Code 2152.10(A)(2)(b) and 2152.12(A)(1)(b), which provide for mandatory transfer of juveniles to adult court in certain circumstances. After a hearing, the juvenile court automatically transferred the case. Appellant moved to dismiss the ensuring indictment charging him with two counts of aggravated robbery with accompanying firearm specifications and transfer his case back to juvenile court, arguing that mandatory transfer of juveniles is unconstitutional. The trial court overruled the motion. Appellant subsequently entered pleas of no contest to the two counts of aggravated robbery. The court of appeals affirmed. The Supreme Court reversed, holding that mandatory transfer of juveniles to adult court without providing for the protection of a discretionary determination by the juvenile court judge violates juveniles’ right to due process. View "State v. Aalim" on Justia Law

After a jury trial, Appellant was found guilty of two counts of murder. The trial court sentenced Appellant to death. The Supreme Court affirmed. Appellant later filed an amended application for postconviction DNA testing pursuant to Ohio Rev. Code 2953.71 through 2953.84. The county common pleas court denied the application. Appellant appealed, arguing that section 2953.73(E)(1) violates the Eighth and Fourteenth Amendments because it discriminates between capital and non-capital criminal defendants, fails to provide appellate review, and results in the arbitrary and capricious application of the death penalty. The Supreme Court held (1) section 2953.73(E)(1) violates the constitutional right to equal protection, but the unconstitutional portion of the statute can be excised to create a constitutionally sound procedure that provides capital offenders an appeal of right to the Supreme Court; and (2) this constitutional analysis applies equally to section 2953.72(A)(8), which summarizes the procedure for appealing a denial of postconviction DNA testing. Therefore, the Court applied the severance remedy to the unconstitutional portions of the statutes. Consequently, Appellant will be permitted an appeal of right to the Supreme Court from the denial of his amended application for postconviction DNA testing. View "State v. Noling" on Justia Law

Relators filed this original action in mandamus seeking the release of video from a camera worn by an officer who shot a motorist after a traffic stop. Relators asserted that Respondent, the prosecuting attorney, violated the Public Records Act by failing either to make the body-camera video available for inspection and copying or to prove that it was exempt from disclosure. The prosecutor released the video two days after the complaint was filed. The Supreme Court dismissed the writ of mandamus as to certain relators because the relators failed to request the record from the prosecutor’s office and denied the writ as to other relators because the body-camera video had already been produced. Because the video was produced within a reasonable amount of time, the request for statutory damages and attorney fees was also denied. View "State ex rel. Cincinnati Enquirer v. Deters" on Justia Law

Appellee pled guilty to a fourth-degree-felony charge of receiving stolen property. The trial court sentenced Appellee to two years of community control and required him to comply with the court’s standard community-control conditions and to pay court costs and probation fees. The trial court later found that Appellee had failed to abide by the requirements of community control. After a hearing, the trial court terminated community control and sentenced Appellee to an eighteen-month prison sentence. Appellee appealed, arguing that the court erred by imposing a sentence without asking him if he wished to exercise his right to allocution. The court of appeals remanded for resentencing, holding that Ohio R. Crim. P. 32(A) and Ohio Rev. Code 2929.19(A) entitled Appellee to make a statement in mitigation of his punishment and that the error was not harmless. The Supreme Court affirmed, holding that a trial court must afford an offender an opportunity for allocution at a community-control-revocation hearing before imposing a sentence for violating the conditions of community control. View "State v. Jackson" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated murder, among other crimes. Defendant was sentenced to death. The Supreme Court affirmed Defendant’s convictions and sentence, holding (1) defense counsel’s absences did not violate Defendant’s rights to counsel or due process; (2) the trial court did not violate Defendant’s rights to due process and a fair trial when it denied his motion for relief from prejudicial joinder; (3) trial counsel did not provide ineffective assistance with regard to two suppression issues; (4) no prejudicial error occurred with how the jury view was conducted; (5) no prejudicial error occurred with regard to the evidence submitted at trial; (6) the trial court did not err by denying Defendant’s Ohio R. Crim. P. 29 motion; (7) no prejudicial error occurred during the sentencing phase of trial; and (8) Defendant death sentence was appropriate and proportional. View "State v. Spaulding" on Justia Law

In 2011, the Lucas County Court of Common Pleas convicted Appellant of two counts of vehicular assault. The judgment entry sentenced Appellant to a term of imprisonment and ordered him to “pay restitution in an amount to be determined at a hearing.” The court of appeals granted in part and denied in part the requested writs, holding that Appellant’s original sentencing entry was not a final, appealable order because it failed to specify the amount of restitution ordered as part of his sentence but that Appellant was not entitled to a de novo resentencing hearing to correct the error. Instead, the court ordered the trial court to issue a sentencing entry that constituted a final appealable order. The trial court subsequently entered a nunc pro tunc order correcting the 2011 entry by omitting the language in the 2011 entry ordering Appellant to pay restitution. Appellant appealed, arguing that he was entitled to a de novo resentencing hearing and that a nunc pro tunc entry cannot be issued to correct the error in the original sentencing entry. The Supreme Court affirmed, holding that Appellant failed to demonstrate that he had a clear legal right to a de novo resentencing hearing. View "State ex rel. Winfree v. McDonald" on Justia Law

Appellee was an eighteen-year-old high school student when he allegedly committed criminal acts that led to his conviction of attempted robbery and attempted complicity in the commission of intimidation. Appellee later applied to the trial court to seal the records pertaining to his conviction. The State argued that Ohio Rev. Code 2953.36 prohibiting the sealing of the record of Appellee’s conviction because the statute prohibits the sealing of records of convictions of an offense of violence when the offense is a felony. The trial court denied Appellee’s application. The court of appeals reversed. The Supreme Court reversed, holding that attempted robbery is a crime of violence and that, pursuant to section 2953.36, a person convicted of attempted robbery is ineligible to have the record of that conviction sealed. View "State v. V.M.D." on Justia Law

After a jury trial, Appellant was convicted of aggravated murder and other offenses. The trial court sentenced Appellant to death for the murder conviction. The Supreme Court affirmed Appellant’s convictions and sentence, holding (1) the trial court did not err in admitting statements Appellant made during his interview with police; (2) Appellant did not receive ineffective assistance of counsel during voir dire or during trial; (3) the trial court did not err by failing to hold a hearing to determine a witness’s competency to testify; (4) the trial judge was not biased against Appellant, and the trial judge did not err by refusing to grant a mistrial for the judge’s alleged biased interjections; (5) Appellant failed to establish plain error regarding the prosecutor’s closing statements; and (6) Appellant’s sentence was appropriate and proportional. View "State v. Cepec" on Justia Law