Justia Ohio Supreme Court Opinion Summaries

Appellant, a private citizen, filed a complaint seeking a writ of mandamus compelling Appellees, the Columbiana County clerk of courts and the Columbiana County prosecutor, to accept for filing an affidavit alleging a criminal offense and to prosecute a named individual for perjury. The court of appeals dismissed Appellant’s complaint in mandamus. The Supreme Court affirmed, holding that Appellant had no clear legal right to a prosecution where the clerk had no clear duty to accept Appellant’s affidavit for filing and the prosecutor had no clear duty to prosecute the alleged crime. View "State ex rel. Capron v. Dattilio" on Justia Law

Appellee was arrested for operating a vehicle while under the influence (OVI). Because he had been convicted of OVI five times in the previous twenty years, Appellee was charged with two fourth-degree felonies under Ohio Rev. Code 4511.19(G)(1)(d) and the repeat-OVI specification described in Ohio Rev. Code 2941.1413 for each offense. Appellee moved to dismiss the repeat-OVI specification attached to each count, arguing that section 2941.1413 violates equal protection because it allows the State to seek greater punishment without providing proof beyond that required to trigger section 4511.19(G)(1)(d). The trial court denied the motion to dismiss, and Appellee pled no contest to both counts. The Court of Appeals reversed, holding that section 2941.1413 violates equal protection. The Supreme Court reversed, holding that section 4511.19(G)(1)(d) and section 2941.1413 are part of a logical, graduated system of penalties for recidivist OVI offenses and do not violate equal protection. View "State v. Klembus" on Justia Law

Appellee was arrested for operating a vehicle while under the influence (OVI). Because he had been convicted of OVI five times in the previous twenty years, Appellee was charged with two fourth-degree felonies under Ohio Rev. Code 4511.19(G)(1)(d) and the repeat-OVI specification described in Ohio Rev. Code 2941.1413 for each offense. Appellee moved to dismiss the repeat-OVI specification attached to each count, arguing that section 2941.1413 violates equal protection because it allows the State to seek greater punishment without providing proof beyond that required to trigger section 4511.19(G)(1)(d). The trial court denied the motion to dismiss, and Appellee pled no contest to both counts. The Court of Appeals reversed, holding that section 2941.1413 violates equal protection. The Supreme Court reversed, holding that section 4511.19(G)(1)(d) and section 2941.1413 are part of a logical, graduated system of penalties for recidivist OVI offenses and do not violate equal protection. View "State v. Klembus" on Justia Law

Appellant was convicted of rape of his former stepson and gross sexual imposition on both his former stepson and former stepdaughter. The trial court’s judgment was affirmed on appeal. Appellant later filed a petition for a writ of habeas corpus, arguing that the trial court lacked jurisdiction to convict him of the rape of his former stepson. The Court of Appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant was not entitled to a writ of habeas corpus because the trial court did not lack subject-matter jurisdiction over his case. View "Leyman v. Bradshaw" on Justia Law

James Smith was indicted on one count of aggravated burglary and one count of rape. Smith was subsequently reindicted on the same two counts, in addition to one count of cocaine possession. Thereafter, the trial court dismissed the earlier indictment. Defendant was found guilty of aggravated burglary and rape. Smith later filed a motion for a new trial, arguing that he received ineffective assistance of counsel because he was convicted on a dismissed indictment. The trial court denied the motion. Smith then filed this original action in the Court of Appeals seeking a writ of prohibition against Judge Michael Hall and his successor, Judge Dennis Adkins, asserting that Judge Hall lacked jurisdiction in his case because his conviction arose from an indictment that had been dismissed prior to trial. The Court of Appeals dismissed Smith’s complaint for a writ of prohibition, determining that a writ of prohibition was not appropriate. The Supreme Court affirmed, holding that Appellant had adequate remedies in the ordinary course of law. View "State ex rel. Smith v. Hall" on Justia Law

Appellant was convicted of aggravated murder with two felony-murder specifications. Appellant was sentenced to death. After Appellant exhausted his postconviction and federal remedies, the Supreme Court ordered the execution to proceed on September 15, 2009. During the scheduled execution, attempts to insert an IV catheter were unsuccessful. Appellant was injected eighteen times during the botched attempt. Appellant pursued multiple avenues challenging any further attempt by the State to execute him. This appeal arose from Appellant’s successive petition for postconviction relief, in which he asserted that any future attempt to execute him would violate the Cruel and Unusual Punishments and Double Jeopardy Clauses of the United States and Ohio Constitutions. The trial court denied Appellant’s petition without an evidentiary hearing. The Court of Appeals affirmed. The Supreme Court affirmed, holding that the State was not constitutionally barred from carrying out Appellant’s execution. View "State v. Broom" on Justia Law

After a jury trial, Defendant was found guilty of one count of manufacturing methamphetamine in the vicinity of a juvenile, a felony. The trial court sentenced Defendant to ten years’ imprisonment. The maximum possible term was eleven years. Defendant appealed, arguing that the trial court abused its discretion by imposing a near-maximum prison term. The Court of Appeals refused to apply an abuse-of-discretion standard to felony-sentencing appeals and affirmed Defendant’s sentence. The Supreme Court affirmed, holding (1) pursuant to Ohio Rev. Code 2953.08(G)(2), an appellate court may vacate or modify a felony sentence on appeal only if it finds by clear and convincing evidence that the record did not support the sentencing court’s decision or that the sentence was otherwise contrary to law; and (2) the Court of Appeals applied the correct standard of review in this case. View "State v. Marcum" on Justia Law

Defendant pled guilty to two counts of receiving stolen property, one a felony and the other a misdemeanor. The court of common pleas ordered Defendant to serve the felony and misdemeanor sentences consecutively. Defendant appealed, arguing that a sentencing order running a jail term for a misdemeanor consecutively to a prison sentence for a felony is contrary to Ohio Rev. Code 2929.41. The court of appeals reversed the part of the trial court’s order that imposed the two sentences consecutively and modified the sentence to run the terms of confinement concurrently. The Supreme Court affirmed, holding that a trial court may not impose consecutive sentences for felony and misdemeanor convictions under Ohio Rev. Code 2929.41(B)(1). Remanded. View "State v. Polus" on Justia Law

In 2006, Appellant was convicted of one count of rape and three counts of gross sexual imposition (GSI). Appellant was sentenced to life in prison for the rape conviction and four years for each of the three GSI convictions. The sentence for one of the GSI convictions was to be served concurrently with the life sentence, and the sentences for the other two GSI convictions were to be served consecutively to each other and to the life sentence. In 2015, Appellant filed this original action for a writ of habeas corpus asserting that he had served the minimum required eight years for two counts of GSI and was therefore eligible for parole. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant was not entitled to relief in habeas corpus because his maximum sentence had not expired and he had available various remedies to challenge his sentence by way of appeal and in postconviction relief and mandamus proceedings. View "State ex rel. Lockhart v. Sheldon" on Justia Law

Appellant was convicted of rape, attempted murder, kidnapping, and burglary. Appellant later filed a petition for postconviction relief, which was untimely. The trial judge denied the petition without issuing findings of fact or conclusions of law. Appellant subsequently filed this action requesting a writ of mandamus compelling the judge to issue findings of fact and conclusions of law with respect to the denial of his postconviction relief petition. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant’s petition for a writ of mandamus was properly denied where Appellant had no clear legal right to the relief he requested, the trial judge had no clear duty to provide it, and Appellant had an adequate remedy at law. View "State ex rel. Dillon v. Cottrill" on Justia Law