Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing two complaints Appellant filed seeking writs of mandamus and prohibition, holding that Appellant was not entitled to writs of mandamus or prohibition vacating his convictions and sentence.Appellant filed both a complaint for a writ of mandamus seeking to compel the trial court to vacate his criminal convictions and sentence and a complaint for a writ of prohibition against the trial court raising the same underlying issues. The court of appeals denied the writs, holding (1) Appellant had an adequate remedy in the ordinary course of the law through direct appeal to challenge any violation of his right to counsel; and (2) Appellant was not entitled to a writ requiring the trial court to review issues related to the withdrawal of his counsel on direct appeal. View "State ex rel. Boyd v. Tone" on Justia Law

The Supreme Court vacated its decision in State v. Gwynne, __ N.E.3d __ (Ohio 2022) (Gwynne IV) and affirmed the judgment of the Fifth District Court of Appeals in this sentencing dispute, holding that the court of appeals properly applied the plain language of Ohio Rev. Code 2953.08(G)(2) in concluding that the record supported the trial court's consecutive sentence findings.Appellant pleaded guilty to seventeen counts of second-degree burglary, among other offenses. The trial court made the findings required under Ohio Rev. Code 2929.14(C)(4) for imposing consecutive sentences and ordered the felony sentences to be served consecutively, for an aggregate sentence of sixty-five years. The appellate court affirmed. The Supreme Court reversed in Gwynne IV, holding on de novo review that the findings required by section 2929.14(C)(4) to impose consecutive prison sentences on an offender must be made in consideration of the aggregate term. The Supreme Court then granted the State's motion for reconsideration, vacated its decision in Gwynne IV and affirmed the court of appeals, holding (1) Ohio Rev. Code 2953.08(G)(2) requires an appellate court to defer to a trial court's consecutive sentence findings, and those findings must be upheld unless they are clearly and convincingly not supported by the record; and (2) the appellate court properly applied that standard. View "State v. Gwynne" on Justia Law

The Supreme Court denied mandamus relief in this action brought under Ohio's Public Records Act, Ohio Rev. Code 149.43, by Kevin Payne against Kelly Rose, an inspector at the Richland Correctional Institution (RCI), holding that Payne did not have a cognizable claim in mandamus.Payne, an inmate at RCI, sent a public-records request to Rose for a copy of, among other things, JPay support ticket number MACI 1220002928. Rose responded that she obtained the requested record and provided a copy of it to Payne. Payne brought this action seeking a writ of mandamus ordering Rose to produce the requested record and statutory damages. The Supreme Court denied mandamus relief, holding (1) because Payne received his requested record before instituting this action he never had a cognizable claim in mandamus; and (2) statutory damages did not accrue. View "State ex rel. Payne v. Rose" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's conviction for violating Ohio Rev. Code 2907.06(A)(2), holding that a jury can reasonably infer that a defendant knew a victim to be substantially impaired so as to convict him of sexual imposition under the statute.Defendant was charged with violating Ohio Rev. Code 2907.06(A)(1) and (2) for his sexual contact with woman who was blind and suffered from unspecified developmental disabilities. The jury found Defendant guilty of both counts of sexual imposition. The court of appeals reversed Defendant's conviction for violating section 2907.06(A)(2), concluding that the victim was not substantially impaired. The Supreme Court reversed, holding (1) knowledge of a victim's "substantial impairment" can be proved both by the defendant's knowledge of the victim's blindness and evidence of the nature of the interactions between the defendant and the developmentally disabled victim; and (2) there was sufficient evidence to find that Defendant knew that the victim's blindness, together with her developmental disabilities, substantially impaired her ability to appraise the nature of and control of Defendant's conduct. View "State v. Jordan" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition ordering the trial court to vacate his criminal sentence, holding that Appellant was not entitled to a writ of mandamus or prohibition.Appellant was convicted of escape, retaliation, and other offenses and sentenced to 26.5 years in prison. Appellant later brought the current action seeking writs of prohibition and mandamus ordering the trial court to vacate his sentencing entries and to grant any other relief to which he was "entitled." The court of appeals dismissed the complaint for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law through direct appeal to raise his claim that the Sixth Amendment requires that a defendant be expressly informed of his right to counsel at each critical stage of the proceeding and that the trial court's failure to do so in his case rendered his sentence void. View "State ex rel. Rarden v. Butler County Common Pleas Court" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus arguing that the trial court in which he was convicted lacked subject-matter jurisdiction, holding that the court of appeals correctly dismissed the petition for Appellant's failure to comply with Ohio Rev. Code 2969.25(C).Appellant was convicted on two counts of aggravated murder and sentenced to two concurrent life sentences. Appellant later filed a petition for writ of habeas corpus alleging that the trial court lacked subject matter jurisdiction and failed properly to journalize his sentencing entry. The court of appeals dismissed the petition for Appellant's failure to comply with section 2969.25(C). The Supreme Court affirmed, holding that the petition was properly dismissed due to Appellant's failure to submit a certified statement of his inmate account, as required by section 2969.25(C)(1). View "Grinnell v. Cool" on Justia Law

The Supreme Court dismissed Appellant's appeal challenging the decision of the court of appeals denying his motion for leave to continue a mandamus action, holding that Appellant's appeal was prohibited under Ohio Rev. Code 2323.52(G).Appellant filed a complaint for a writ of mandamus alleging that he made a public-records request to Appellee, Franklin County Prosecutor G. Gary Tyack, under Ohio's Public Records Act, Ohio Rev. Code 149.43, for certain documents, and that Tyack had failed to answer his request. Thereafter, in a separate case, Mobley was declared a vexatious litigator. Mobley filed a motion for leave to continue his mandamus action as a vexatious litigator, but the court of appeals denied the motion and dismissed the mandamus action. The Supreme Court dismissed Appellant's appeal, holding that the Court lacked jurisdiction to consider the appeal. View "State ex rel. Mobley v. Tyack" on Justia Law

In this case concerning how an Ohio prisoner is to enforce his constitutional right to a speedy trial on an untried indictment the Supreme Court held that a prisoner satisfies the "causes to be delivered" requirement of Ohio Rev. Code 2941.401 when he delivers the written notice and the request to the warden where he is imprisoned, even if the warden fails to deliver the notice and the request to the prosecuting attorney or the appropriate court.Appellant, who was indicted on counts of aggravated robbery and robbery, moved to dismiss the indictment on speedy-trial grounds. The trial court granted the motion, concluding that Appellant had strictly complied with section 2941.401 when he provided written notice of his place of imprisonment and a request for a final disposition and that the 180-day speedy trial time was not tolled by the warden's failure to comply with his duty to send out Appellant's written notices and requests to the prosecuting attorney or the appropriate court. The court of appeals reversed, concluding that Appellant had not strictly complied with the requirements of the statute. The Supreme Court reversed, holding that Appellant caused to be delivered his written notice and request for final disposition under the statute when he provided them to the warden. View "State v. Williams" on Justia Law

The Supreme Court granted a limited writ of mandamus ordering Respondent James Wesson, the warden's assistant at the Grafton Correctional Institution (CGI), to, within fourteen days, either produce records in response to a December 2022 public-records request or show cause why the records could not be produced, holding that Relator was entitled to the writ.Relator, an inmate at CGI, sent a public-records request by electronic kite to Wesson requesting three records. Relator subsequently commenced this mandamus action asking the Court to order Wesson to provide the requested records. The Supreme Court granted a limited writ ordering Wesson to produce a copy of a mental-health kite with reference number GCI0422002492 from April 21, 2022 or to show cause why it could not be produced, holding that Relator established that he was entitled to the writ. View "State ex rel. Barr v. Wesson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's convictions for felony charges stemming from an inventory search of an impounded truck that Defendant was driving when he was pulled over by a law enforcement officer, holding that the search was reasonable and lawful under the Fourth Amendment.Law enforcement performed an inventory search as to the truck at issue and found a handgun in the truck's right door panel. After Defendant unsuccessfully moved to suppress the evidence of the gun the trial court found him guilty. The court of appeals reversed, holding that the search was not reasonable under the Fourth Amendment because the state's evidence was insufficient. The Supreme Court reversed, holding that the inventory search was lawful. View "State v. Toran" on Justia Law