Justia Ohio Supreme Court Opinion Summaries

Pursuant to a plea agreement, Appellant pleaded guilty to three counts of raping his minor biological daughter. The judge imposed the jointly recommended sentence of three eight-year prison terms to be served consecutively to each other. The court of appeals vacated Appellant’s sentence, holding that while a jointly recommended sentence that is “authorized by law” is not subject to review, Appellant’s sentence was appealable and must be vacated because the trial court did not make the findings required by Ohio Rev. Code 2929.14(C)(4) for imposing consecutive sentences at the sentencing hearing. The Supreme Court reversed, holding (1) compliance with section 2929.14(C)(4) was not necessary because the consecutive sentences were jointly recommended and imposition of consecutive sentences for multiple counts of rape under Ohio Rev. Code 2907.02 is discretionary, not mandatory; and (2) therefore, Appellant’s sentence was “authorized by law” and not subject to review on appeal. View "State v. Sergent" on Justia Law

In 2003, Appellant was convicted of two counts of rape. The sentencing entry stated that Appellant “shall be subject to post release control of up to three years.” The trial court later journalized a nunc pro tunc order correcting the 2003 order by stating that Appellant “shall be subject to post release control of up to five years.” After completing his term of incarceration, Appellant filed a motion to terminate postrelease control. The court of common pleas found that the motion was actually a petition for postconviction relief and dismissed it as untimely. Appellant filed filed an action in mandamus and/or prohibition requesting a writ compelling the trial court to issue a valid final judgment in the underlying case. The court of appeals dismissed the petition, concluding that the trial court lost jurisdiction to take action in the criminal case where Appellant had served the maximum prison term. The Supreme Court affirmed on the basis that Appellant had an alternate remedy in the ordinary course of law by way of appealing the trial court’s dismissal of his motion to terminate his postrelease control. View "State ex rel. Rudert v. Collier" on Justia Law

In 1991, Larry Dawson was convicted of aggravated murder and other crimes. In 2012, Dawson filed a motion for an oral hearing to correct a “void” sentence on the alleged ground that the entry did not address all the charges. Judge Lynne Callahan denied the motion. Dawson appealed. The appellate court concluded that the original sentencing entry was a final, appealable order and that Dawson’s sentencing entry disposed of all charges against him. In 2014, Dawson moved the court to issue a valid judgment. Judge Callahan denied the motion. Dawson then petitioned the Court of Appeals for a writ of mandamus and/or procedendo ordering Judge Callahan and the Summit County Court of Common Pleas (collectively, Respondents) to resentence him and issue a final judgment of conviction. The Court of Appeals concluded that Dawson was not entitled to either writ. The Supreme Court affirmed, holding that because Dawson could have raised the issues in his direct appeal that he asserts now, and because the same issue had already been addressed in the appeal of Dawson’s motion for a new sentence, the case is res judicata. View "State ex rel. Dawson v. Summit County Court of Common Pleas" on Justia Law

After a bench trial, Defendant was found guilty of domestic violence, a misdemeanor in the first-degree. During trial, the victim asserted the privilege against self-incrimination at least eight times in response to questions posed to him about Defendant’s assault. Defendant appealed, raising four claims of error. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by the trial court’s inquiry into the victim’s claim of privilege nor by the trial court’s instruction to the victim to read his prior statement during his examination; (2) Defendant failed to establish that an impermissible judicial bias deprived him of a fair trial; and (3) assuming the trial court erred in allowing the victim to read his prior statement at trial, the error was harmless beyond a reasonable doubt. View "State v. Arnold" on Justia Law

Defendant pleaded guilty to the rape and murder of his grandmother and the murder of her husband. Defendant was sentenced to death for the aggravated murders. The Supreme Court affirmed the convictions and death sentences, holding (1) the trial court did not improperly deny Defendant’s request for self-representation; (2) the trial court did not violate Defendant’s right against self-incrimination when it denied Defendant’s motion to suppress certain statements he made; (3) Defendant’s challenges to the trial court’s evidentiary rulings were unavailing; (4) Defendant’s counsel provided constitutionally effective assistance; (5) any misconduct on the part of the prosecutor was not prejudicial; (6) there were no prejudicial errors in the sentencing opinion; and (7) the imposition of the death sentences was appropriate and proportional. View "State v. Obermiller" on Justia Law

Defendant entered a no-contest plea to charges of aggravated robbery and aggravated murder with capital specifications. Defendant was sentenced to death for the murder. The Supreme Court affirmed Defendant’s convictions and death sentence, holding (1) Defendant’s constitutional challenges to Ohio’s death penalty laws were unavailing; (2) the trial court erred by denying one of seven pretrial motions Defendant filed, but in so doing, the trial court did not undermine Defendant’s right to a jury trial; (3) the trial court did not err by denying Defendant’s motion to have a copy of the prosecutor’s complete file turned over to the court for review; (4) the trial court correctly denied Defendant’s motions to suppress his confession; (5) the trial court did not err by admitting fingerprint evidence; (6) the prosecutor did not engage in impermissible misconduct; (7) Defendant received effective assistance of counsel; and (8) Defendant’s death sentence was appropriate. View "State v. Belton" on Justia Law

Appellant was convicted of murder. While incarcerated, Appellant filed a motion to vacate his conviction and sentence. When the trial court took no action on his motion, Appellant filed a petition in procedendo in the court of appeals. Thereafter, the county court of common pleas judge denied Appellant’s trial court motion. The judge then filed a motion to dismiss in the procedendo action. The motion was converted to one for summary judgment, and the writ was denied. The Supreme Court affirmed, holding that Appellant’s action in procedendo was moot, as the trial judge ruled on Appellant’s motion to vacate. View "State ex rel. Morgan v. Fais" on Justia Law

John Nye was convicted of a violation of a city ordinance. Judge Lisa Coates, the trial court judge in the case, adopted and approved the magistrate’s decision. However, there was no order in the record that set forth a finding of guilt with the imposition of a sentence. Nye appealed. While the appeal was questioned for want of a final, appealable order, it was ultimately dismissed for failure to prosecute. Thereafter, Nye filed an action in precedendo against Judge Coates. The court of appeals granted the writ, concluding that, in a criminal matter, a trial court must enter judgment separately on all claims and may not simply refer to the magistrate’s decision. Judge Coates subsequently filed a new order that complied with Ohio R. Crim. P. 32(C). Nye appealed, asserting, as he did in the court below, a right to a magistrate’s decision that complies with the form requirements of Ohio R. Crim. P. 19(D)(3)(a)(iii) and a right to findings of fact and conclusions of law from the magistrate. The Supreme Court dismissed the appeal, holding that Nye had an adequate remedy in the ordinary course of law, precluding a writ. View "State ex rel. Nye v. Coates" on Justia Law

Appellant was found guilty of disorderly conduct. In appealing that judgment pro se, Appellant filed a complaint for a writ of mandamus under the same case number as the appeal. Appellant also filed a motion for a stay of the appeal proceedings pending resolution of the mandamus action. The court of appeals struck the complaint on the grounds that a mandamus action is not properly filed as a pleading in a pending appeal. Appellant appealed the court of appeals’ entry striking the mandamus complaint as well as subsequent entries issued by the court of appeals. The Supreme Court dismissed the appeal in part and affirmed in part, holding (1) as to four of the court of appeals’ entries, Appellant’s appeal is dismissed because his notice of appeal is untimely; and (2) to the extent that later entries pertain to Appellant’s mandamus action, the court of appeals is affirmed. View "State v. Henry" on Justia Law

Appellant filed a pleading in the court of appeals entitled “Eighth Admendment [sic] Violation” seeking an order compelling a county jail to send medical records pertaining to treatment he received while he was there to the correctional institution where he is currently incarcerated. The court of appeals construed Appellant’s pleading as a petition for a writ of mandamus and then dismissed his case for failing to follow procedural requirements. The Supreme Court affirmed, holding that the court of appeals did not err by dismissing Appellant’s mandamus petition because he failed to comply with the mandatory filing requirements of Ohio Rev. Code 2969.25. View "State v. Henton" on Justia Law