Justia Ohio Supreme Court Opinion Summaries

Appellant, who is serving a life sentence on a conviction for aggravated murder, filed a petition for a writ of habeas corpus, asserting that he remained in prison solely under an order that the trial court lacked jurisdiction to issue. The claim was unsuccessfully raised in one of Appellant’s prior petitions for habeas corpus. The court of appeals dismissed the case on grounds of res judicata. The Supreme Court remanded the case for the appellate court to convert the motion to dismiss into a motion for summary judgment and to provide Defendant with notice and an opportunity to respond. The court of appeals again dismissed the petition on remand. The Supreme Court affirmed, holding that Defendant’s habeas claim was barred by the doctrine of res judicata. View "Jefferson v. Bunting" on Justia Law

Defendant was charged with operating a motor vehicle under the influence of alcohol. Defendant filed a motion to suppress the evidence obtained against him, including laboratory and chemical tests of his alcohol level. The trial court granted the motion. The appellate court affirmed, ruling that the State had failed to establish substantial compliance with Ohio Adm. Code 3701-53-05(F) because it allowed a blood sample to remain unrefrigerated for four hours and ten minutes before it was placed in the mail, and therefore, Defendant’s blood-alcohol test results were inadmissible. The Supreme Court reversed, holding that the State demonstrated substantial compliance with Ohio Adm. Code 3701-53-05’s requirement that blood be refrigerated, but, in conformity with State v. Burnside, the case is remanded to provide Baker with an opportunity to rebut the presumption of admissibility. View "State v. Baker" on Justia Law

A jury found Appellant guilty of aggravated murder, attempted murder, aggravated robbery, and kidnapping. The trial court imposed a sentence of life imprisonment without parole eligibility for thirty years for the aggravated-murder conviction. Appellant later filed a motion for a final, appealable order and resentencing, arguing that because his sentencing entry did not state the reasons why the mitigating factors outweighed the aggravating circumstances, it was not a final, appealable order. The trial court denied the motion, concluding that it was not required to file a written sentencing opinion where the jury recommended a sentence other than death. Thereafter, Appellant filed a petition for a writ of mandamus seeking an order compelling Judge Judge Michael Russo to issue a separate sentencing opinion. The court of appeals dismissed Appellant’s complaint for writ of mandamus. The Supreme Court affirmed, holding that Appellant did not have a clear legal right to a separate sentencing opinion and that the Judge Russo did not have a clear legal duty to provide one. View "State ex rel. Stewart v. Russo" on Justia Law

Relator was convicted of having an unlawful interest in a public contract and was sentenced to six months in jail. Relator sought writs of prohibition, mandamus, and habeas corpus. The Supreme Court denied the writs by ordered that Relator’s sentence be stayed pending resolution of her appeal. The court of appeals subsequently affirmed the conviction. Relator then filed a motion in the court of appeals for en banc reconsideration. Relator asked the trial court judge to stay execution of her sentence, but he declined. Thereafter, Relator filed this action for a writ of prohibition to prevent the trial court judge from executing her sentence until, among other conditions, the court of appeals decided her motion for en banc reconsideration. The Supreme Court denied the writs and dismissed the case, holding (1) because there was no order of this Court prohibiting the trial court judge from exercising judicial authority there was no basis upon which to issue a writ of prohibition to the judge; and (2) because the sheriff would not be exercising judicial authority in admitting Relator into jail, the issuance of a writ of prohibition against him would be inappropriate. View "State ex rel. Hunter v. Dinkelacker" on Justia Law

This appeal involved Defendant’s motion to suppress evidence of a gun that was found in a search of a car legally parked on a public street that Defendant was sitting in just before his arrest on a warrant for domestic violence. After Defendant was arrested, an officer conducted an inventory search of the car, during which he found a handgun. The district court denied Defendant’s motion to suppress, concluding that there was probable cause to arrest Defendant based on the domestic-violence warrant and that, pursuant to that arrest, the inventory search of the car prior to towing was proper. The Supreme Court reversed, holding that the warrantless inventory search of the lawfully parked vehicle in this case was unreasonable under the Fourth Amendment to the United States Constitution and Ohio Const. art. I, 14. View "State v. Leak" on Justia Law

Defendant was convicted of tampering with evidence for concealing heroin within a body cavity. The court of appeals affirmed Defendant’s tampering conviction, concluding that at the time Defendant concealed the heroin in her body cavity, Defendant had constructive knowledge of an impending investigation. At issue on appeal was whether a person who hides evidence of a crime that is unmistakable to him or her commits tampering with evidence in the absence of evidence that a victim or the public would report a crime. The Supreme Court reversed, holding (1) Ohio law does not impute constructive knowledge of an impending investigation based solely on the commission of an offense, and therefore, the fact that an act was unmistakably a crime does not in itself establish that the defendant knew of an investigation into that crime or that such an investigation was likely to be instituted; and (2) in this case, Defendant’s tampering conviction was not supported by sufficient evidence because there was no evidence that, at the time she concealed the heroin in her body, Defendant knew or could have known that a state trooper would stop her car and begin an investigation of her for drug trafficking and drug possession. View "State v. Barry" on Justia Law

Relator was indicted on two counts of felonious assault and one count of aggravated burglary. One of the felonious-assault counts was subsequently amended. After a jury trial, Relator was convicted of aggravated burglary and one count of felonious assault, the jury being unable to reach a verdict as to the amended felonious-assault count. The sentencing entry did not dispose of the amended felonious-assault charge. The state later indicted Relator on two new charges under the same case number. The sentencing entry memorializing a plea deal involving the posttrial indictments failed to address the unresolved felonious-assault charge from trial. The trial judge finally signed an entry dismissing the felonious-assault charge, but the court’s order dismissed the charge “as indicted,” without disposing of the charge as amended before trial. Relator sought a writ of mandamus compelling the issuance of a final, appealable order in his criminal case. The County filed a motion to dismiss based on res judicata. The Supreme Court denied the County’s motion to dismiss - as res judicata did not apply where the trial court never issued a final, appealable order - and issued a peremptory writ directing the County to issue a final, appealable order disposing of all the charges against Relator. View "State ex rel. McIntyre v. Summit County Court of Common Pleas" on Justia Law

In 1998, Defendant was convicted of aggravated murder and sentenced to death. Defendant later sought habeas corpus relief, alleging that he had received ineffective assistance of counsel at trial. The federal court granted relief, concluding that Defendant had received ineffective assistance of trial counsel during the mitigation phase of his trial. After a new mitigation hearing over which a new judge presided, twelve new jurors recommended a sentence of death. The trial court again imposed a death sentence. The Supreme Court vacated the sentence of death and remanded for resentencing, holding (1) there were no significant procedural defects in the new mitigation hearing; but (2) pursuant to the Court’s independent evaluation of the sentence under Ohio Rev. Code 2929.05(A), the aggravating circumstances that Defendant was found guilty of committing did not outweigh beyond a reasonable doubt the mitigating factors. Remanded for resentencing. View "State v. Johnson" on Justia Law

Defendant pled guilty to one count of unlawful sexual conduct with a minor who was over thirteen but less than sixteen years of age. Defendant, who was twenty-one years old when he committed the offense, was designated a Tier II sex offender/child-victim offender and was required to register with the county sheriff and to verify his residence address every 180 days for twenty-five years. Defendant appealed, arguing that the Tier II sex-offender requirements imposed upon him violated the Eighth Amendment’s prohibition against cruel and unusual punishment. The court of appeals affirmed. The Supreme Court affirmed, holding that the registration and address-verification requirements for Tier II offenders under Ohio Rev. Code 2950 do not constitute cruel and unusual punishment. View "State v. Blankenship" on Justia Law

Appellant pleaded guilty to aggravated vehicular assault, endangering children, and operating a motor vehicle under the influence of alcohol or drugs (OVI). The trial court sentenced Appellant to a term of three years for aggravated vehicular assault, thirty-six months for endangering children, and six months for OVI, all sentences to run concurrently. Appellant challenged her sentences on appeal, arguing that aggravated vehicular assault is an allied offense of OVI and that the two offenses should have merged. The court of appeals affirmed, concluding that even if aggravated vehicular assault and OVI are allied offenses, Ohio Rev. Code 2929.41(B)(3) creates and exception that permits a trial court to impose a sentence for both. The Supreme Court affirmed, holding that a trial court may impose cumulative sentences for both aggravated vehicular assault and OVI when the offense of OVI is the predicate conduct for aggravated vehicular assault. View "State v. Earley" on Justia Law