Justia Ohio Supreme Court Opinion Summaries

Appellant was found guilty of two counts of aggravated murder and was sentenced to death on each count. The appellate court reversed the convictions and remanded for a new trial. The Supreme Court affirmed and remanded the case on the basis of an error in the trial court’s evidentiary rulings and a Brady violation. Upon his release from prison, Appellant filed a claim for wrongful imprisonment pursuant to Ohio Rev. Code 2743.48. The trial court dismissed the claim, concluding that Appellant failed to meet his statutory burden of proving by a preponderance of the evidence that he did not commit the murders. Thereafter, another individual pleaded guilty to the murders for which Appellant was found guilty, and the legislature amended section 2743.48 to expand the definition of a wrongfully imprisoned individual to include those released as a result of a procedural error occurring subsequent to sentencing. Thereafter, Appellant filed a second claim for wrongful imprisonment. The trial court ultimately declared Appellant to be a wrongfully imprisoned individual. The appellate court reversed, concluding that the amended statute did not apply retroactively to Appellant’s alleged injury. The Supreme Court reversed, holding that section 2743.48 applied retroactively to permit litigation of Appellant’s claim. View "Johnston v. State" on Justia Law

Defendant was found guilty of two counts of aggravated murder and six counts of attempted murder. Defendant was sentenced to death. On appeal, the Supreme Court reversed Defendant’s convictions, vacated the death sentence, and remanded for a new trial. After a new jury was convened, Defendant was convicted on all charges and specifications and again sentenced to death. The Supreme Court affirmed the convictions and sentence of death, holding (1) no error occurred in the selection and removal of jury members; (2) the trial court did not make erroneous evidentiary rulings that denied him a fair trial; (3) the trial court did not err in its instructions to the jury; (4) the evidence was sufficient to support the convictions; (5) no prejudicial error occurred during the penalty phase; (6) the prosecutor did not commit misconduct during either the guilt phase or penalty phase of trial; (7) Defendant’s counsel provided effective assistance during both phases of trial; and (8) Defendant’s death sentence was appropriate and proportional. View "State v. Dean" on Justia Law

Relator, who had been convicted of a sexually-oriented offense, was indicted for failure to notify the appropriate county sheriff’s office when he changed his residential address. Relator filed a petition for writ of mandamus in the court of appeals, asserting that Judge Frank G. Forchione lacked jurisdiction over his criminal case for the failure to notify and indicating that only Judge Haas, who presided over his original criminal case, had jurisdiction. The court of appeals granted Judge Forchione’s motion to dismiss. The Supreme Court affirmed, holding that Relator had an adequate remedy in the ordinary course of law by way of appeal was not entitled to a writ of mandamus. View "State ex rel. Black v. Forchione" on Justia Law

After a jury trial, Appellant was convicted of aggravated murder. The trial court sentenced Appellant to death. The Court of Appeals affirmed the conviction and sentence. The Supreme Court affirmed the conviction for aggravated murder but vacated the sentence of death, holding (1) the trial court did not commit prejudicial error in its pretrial rulings or violate Appellant’s right to a speedy trial or fair trial; (2) there was no prejudicial error or violation of Appellant’s constitution rights regarding jury selection; (3) the trial court did not err in denying Appellant’s motion to suppress; (4) Appellant was not prejudiced by prospective juror misconduct, and the trial court did not err in denying Appellant’s motion for a mistrial based on statements made by a witness; (5) Appellant did not receive ineffective assistance of counsel; (6) the jury was properly instructed; but (7) there was not sufficient evidence to support the finding on the capital specification, and therefore, the evidence was insufficient to support the death sentence. Remanded for a new sentencing hearing. View "State v. Adams" on Justia Law

After a jury trial, Defendant was found guilty of operating a vehicle while under the influence of alcohol or drugs (OVI) in violation of Ohio Rev. Code 4511.19(A)(1)(a), a third-degree felony, and a repeat-offender specification; OVI in violation of Ohio Rev. Code 4511.19(A)(1)(d), a third-degree felony; and driving under suspension. The trial court merged the two OVI counts for sentencing purposes and imposed a “mandatory” three-year sentence for the specification plus an additional “mandatory” consecutive five-year sentence for the underlying OVI offense. The Ninth District Court of Appeals vacated the sentence, holding that it was contrary to law, but certified that its decision conflicted with State v. Sturgill, decided by the Twelfth District Court of Appeal. In this certified conflict appeal, the Supreme Court considered how multiple sentencing statutes interact when a defendant is convicted of an OVI offense as a third-degree felony as well as a repeat-offender specification. The Court held that, under these circumstances, a trial court must sentence that defendant to a mandatory prison term of one to five years for the repeat-offender specification and may also sentence the defendant to an additional prison term of nine, twelve, eighteen, twenty-four, thirty, or thirty-six months for the underlying OVI conviction. View "State v. South" on Justia Law

J.T., a juvenile, was charged with carrying a concealed deadly weapon for carrying a broken pistol in his waistband that was no longer capable of firing a round. J.T. was found delinquent. The Supreme Court vacated the finding of delinquency, holding (1) an inoperable pistol that is not used as a bludgeoning implement is not a “deadly weapon” for purposes of Ohio Rev. Code 2923.12, which prohibits carrying a concealed weapon; and (2) therefore, there was insufficient evidence in this case to support J.T.’s finding of delinquency for carrying a concealed weapon. View "In re J.T." on Justia Law

In two separate criminal cases, Appellant was convicted of aggravated menacing and unauthorized use of property. Judge Albert S. Camplese presided over both cases. Appellant filed actions in prohibition against Judge Camplese in both cases, arguing that Judge Camplese lacked jurisdiction over both cases. The court of appeals dismissed both of Appellant’s complaints for prohibition. The Supreme Court affirmed, holding (1) Appellant has alternate remedies at law by way of appeal from the underlying convictions; (2) Judge Camplese did not patently and unambiguously lack jurisdiction over either case; and (3) there was no defect in the criminal complaints in either case. View "State ex rel. Elder v. Camplese" on Justia Law

C.K. was found guilty of murder. The appellate court reversed the conviction as being against the manifest weight of the evidence. On remand, the State dismissed the indictment without prejudice. C.K. later brought this action seeking a declaration that he was a “wrongfully imprisoned individual” and that he cannot and will not be retried for murder. The trial court granted summary judgment for the State, concluding that the mere possibility of being reindicted and retried precluded C.K. from being found to have been wrongfully imprisoned. The court of appeals reversed, concluding that genuine issues of material fact existed regarding whether C.K. was a wrongfully imprisoned individual because the State had not shown that a future criminal proceeding would be factually supportable and legally permissible following the reversal of C.K.’s murder conviction. The Supreme Court reversed, holding that the State’s decision to defer prosecution pending the discovery of stronger evidence of guilt was insufficient to establish that no criminal proceeding can be brought or will be brought against C.K. for any act associated with the murder at issue in this case. Accordingly, there were no genuine issues of material fact, and the State was entitled to judgment as a matter of law. View "C.K. v. State" on Justia Law

Appellant, an inmate, sought several forms of relief challenging the Ohio Department of Rehabilitation and correction’s attachment of money in her prison account. Specifically, Appellant claimed that the money was exempt from garnishment or attachment because it originated from a pension. The court of appeals dismissed Appellant’s entire case without notice. The Supreme Court affirmed in part and reversed and remanded in part, holding that the court of appeals (1) correctly dismissed most of Appellant’s complaint; but (2) erred in dismissing, without notice, Appellant’s mandamus claims regarding, inter alia, the exempt status of the pension money placed in her prison account and, rather, should have allowed Appellant to brief the issues before deciding the merits. View "State ex rel. Williams v. Trim" on Justia Law

Relator, a federal inmate, made a public-records request of Respondent, the chief of police of the Cedar Point Police Department. Alleging that Respondent failed to provide the requested records, Relator sued in mandamus in the court of appeals. The court of appeals dismissed the case, concluding that Relator failed to comply with Ohio Rev. Code 2969.25(C)(2), which requires an inmate’s affidavit of indigency in a suit against a government entity or employee to contain a statement of the inmate’s assets. The Supreme Court reversed, holding (1) the definition of “inmate” for purposes of section 2969.25(C) is a person confined in a state prison and does not include persons in confinement in federal prison; and (2) because Relator is an inmate in a federal prison, the court of appeals erred in dismissing Relator’s complaint for failing to comply with section 2969.25. Remanded. View "State ex rel. Sheets v. Chief of Police" on Justia Law