Justia Ohio Supreme Court Opinion Summaries

Defendant was entered a guilty plea to charges of murder, domestic violence, and aggravated murder with capital specifications for the murders of his former girlfriend, their two-year-old son, and his girlfriend’s nine-year-old daughter. A three-judge panel unanimously sentenced Defendant to death of the aggravated murders of the two children and to fifteen years to life for his girlfriend’s murder. The Supreme Court affirmed Defendant’s convictions and sentence of death, holding (1) the panel did not err by failing sua sponte to order Defendant to undergo a competency evaluation; (2) the evidence presented during the plea hearing was sufficient to convict Defendant of the escaping detection specification attached to an aggravated murder, and defendant’s conviction of that specification was not against the manifest weight of the evidence; (3) defense counsel provided constitutionally effective assistance during the plea and mitigation hearings; (4) Defendant was not denied due process of law and a fair trial when the panel admitted and considered graphic photographs during the plea and mitigation hearings; and (5) Defendant’s death sentence was appropriate and proportionate. View "State v. Montgomery" on Justia Law

Defendant, a police officer, was charged with one count of unlawful sexual conduct with a minor and one count of sexual battery. A bench trial resulted in Defendant’s conviction for sexual battery under Ohio Rev. Code 2907.03(A)(13), which makes peace officers strictly liable for sexual conduct with anyone under the age of eighteen when the offender is more than two years older. The appellate court reversed, concluding that section 2907.03(A)(13) violated equal protection and was facially unconstitutional. The Supreme Court affirmed, holding that the statute is an arbitrarily disparate treatment of peace officers that violates equal protection principles under the state and federal constitutions. View "State v. Mole" on Justia Law

Appellant, an inmate, filed a petition for a writ of habeas corpus arguing that his aggregate sentence had expired and that he was entitled to immediate release. Appellee, Warden Brigham Sloan, moved to dismiss the petition, arguing, among other things, that Appellant failed to state a claim upon which relief could be granted because his sentence did not expire until 2039. The court of appeals granted the motion to dismiss. The Supreme Court affirmed, holding that the habeas petition was properly dismissed because Appellant failed to attach all his required commitment papers to the petition. View "State ex rel. Jackson v. Sloan" on Justia Law

Appellee was charged with rape and kidnapping. Appellee filed a motion to dismiss the indictment based on unconstitutional preindictment delay. The court of common pleas dismissed the charges, concluding that the State’s indictment of Appellee one day before the expiration of the applicable twenty-year statute of limitations prejudiced Appellee. The court of appeals affirmed, concluding that Appellee suffered actual prejudice as a result of the nearly twenty-year delay between the alleged offenses and the indictment. The Supreme Court reversed, holding that the court of appeals applied an incorrect standard in its analysis of Appellee’s preindictment-delay claim. Remanded. View "State v. Jones" on Justia Law

Appellant, an inmate, filed a petition for a writ of mandamus alleging constitutional violations with regard to his conviction and requesting the appointment of a special prosecutor to investigate the propriety of the criminal proceedings brought against him. Appellant filed an affidavit of indigence requesting a waiver of fees and costs but failed to comply with the requirements of Ohio Rev. Code 2969.25(C)(1). The court of appeals’ magistrate recommended that the court dismiss the case for Appellant’s failure to satisfy the statutory requirements. The court of appeals accepted and adopted the magistrate’s decision and recommendation and dismissed the case. The Supreme Court affirmed, holding that the court of appeals correctly dismissed the case on the basis recommended by the magistrate. View "State ex rel. Davenport v. State" on Justia Law

Appellant, an inmate, filed a petition for a writ of habeas corpus claiming that the trial court lacked jurisdiction to convict and sentence him because of several alleged errors. The court of appeals dismissed the petition, concluding that Appellant had adequate remedies at law. Appellant appealed and filed a motion for an evidentiary hearing. The Supreme Court (1) affirmed the court of appeals’ judgment, holding that the claims or which Appellant sought relief were not cognizable in habeas corpus and Appellant had, and has used, adequate remedies at law to assert those claims; and (2) denied Appellant’s motion for an evidentiary hearing as moot. View "State ex rel. Gibson v. Sloan" on Justia Law

Appellant pleaded guilty to involuntary manslaughter and aggravated robbery and was sentenced to nineteen years in prison. Appellant later filed a petition for writ of habeas corpus, alleging several claims of error. The court of appeals dismissed the petition on the ground that Appellant had an adequate remedy in the form of an appeal and a postconviction motion for relief. Appellant appealed. The Supreme Court affirmed, holding that the claims for which Appellant sought relief were not cognizable in habeas corpus and that Appellant possessed an alternative remedy at law to assert those claims. View "State ex rel. Rackley v. Sloan" on Justia Law

Appellant pleaded guilty to one count of gross sexual imposition and was sentenced to eighteen months in prison. After serving his prison sentence, Appellant was released but was still subject to the reporting requirements that were imposed because he was adjudicated a sexual predator. Appellant subsequently filed a petition for a writ of habeas corpus in the court of appeals seeking an order striking his reclassification as a sexual predator applied under Megan’s Law and the AWA Act. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that because Appellant was not in prison or otherwise restrained of his liberty, he was not eligible for habeas corpus relief. View "Cook v. State" on Justia Law

Appellant, an inmate, filed a petition for a writ of mandamus requesting that the court of appeals order the trial court in his underlying criminal case to rule on motions that were allegedly pending. The court’s magistrate recommended that the court dismiss the case for Appellant’s failure to satisfy the requirements of Ohio Rev. Code 2969.25. The court of appeals accepted and adopted the magistrate’s decision and recommendation and dismissed the case. The Supreme Court affirmed, holding that the court of appeals was correct to dismiss the case on the basis recommended by the magistrate. View "State ex rel. Davenport v. State" on Justia Law

Appellant, an inmate, filed a petition for writ of habeas corpus, alleging several claims of error, including ineffective assistance of counsel. The appellate court dismissed Appellant’s petition because he had or has adequate remedies at law to raise these claims. Appellant appealed, challenging the appellate court’s dismissal of his habeas action. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion when it dismissed Appellant’s habeas case because Appellant had or has adequate remedies at law in the form of direct appeal and postconviction relief to raise his claims. View "Kneuss v. Sloan" on Justia Law