Justia Ohio Supreme Court Opinion Summaries

Appellant filed a motion to suppress in his criminal action. Judge Deena R. Calabrese overruled the motion in open court and indicated that she would journalize an entry on the same day. Appellant later filed this action for a writ of mandamus to compel Judge Calabrese to journalize her decision denying the motion to suppress, alleging that the entry was never filed and that he had a right to have the oral decision reduced to writing. The court of appeals granted Judge Calabrese’s motion for summary judgment. The Supreme Court affirmed, holding that the court of appeals (1) correctly found that Appellant failed to comply with Ohio Rev. Code 2969.25(C); and (2) properly granted summary judgment because Judge Calabrese had, in fact, filed an entry on the motion to suppress that sufficiently journalized her decision overruling Jackson’s motion and therefore rendered Jackson’s action in mandamus moot. View "State ex rel. Jackson v. Calabrese" on Justia Law

Appellant, an inmate, was convicted of robbery, aggravated robbery, felonious assault, and other charges. Judge David Fais first sentenced Appellant in 2001. In 2002, the court of appeals reversed and remanded for resentencing. In 2003, Judge Fais again sentenced Appellant. The court of appeals again remanded for resentencing after Appellant’s second and third appeals. In 2006, Judge Fais issued a judgment entry sentencing Appellant for a fourth time. Appellant did not appeal but, instead, filed this action in procedendo, requesting a writ ordering Judge Fais to hold a sentencing hearing in compliance with the court of appeals’ 2002 judgment. The court of appeals granted summary judgment for Judge Fais, concluding that Appellant had an adequate remedy in the ordinary course of law by way of appeal of Judge Fais’s 2006 judgment entry. The Supreme Court affirmed, holding that Appellant was not entitled to a writ of procedendo, as Judge Fais’s 2006 judgment entry sentencing Appellant to prison was an appealable order. View "State ex rel. Elkins v. Fais" on Justia Law

In 1970, Appellant pleaded guilty to aggravated assault and was sentenced to an indeterminate period. Appellant was placed in the custody of the Ohio Department of Rehabilitation and Correction (ODRC), which treated his sentence as a one-to-five-year term authorized by former Ohio Rev. Code 2901.241. The Adult Parole Authority (APA) and the Bureau of Sentence Computation (BOSC) made decisions regarding Appellant’s parole eligibility and release based on the one-to-five-year term. Appellant filed this action in mandamus requesting that Appellees - the ODRC, APA, and BOSC - remove the invalid sentence from their records and no longer make decisions based on it because the sentencing entry did not explicitly set forth the maximum and minimum length of his sentence and that the ODRC, not a court, imposed a sentence of one to five years. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant had adequate remedies in the ordinary course of the law to challenge the sentence and ODRC’s interpretation of the sentence. View "Turner v. Dept. of Rehab. & Corr." on Justia Law

Appellant, an inmate, was convicted of aggravated burglary and rape. Appellant filed this action in habeas corpus alleging that his convictions and sentence were invalid and he must be released. Specifically, Appellant alleged that the trial court had declared a mistrial in a third retrial but failed to place that declaration in a journal entry, and therefore, the trial court did not have jurisdiction over him for a fourth trial. The court of appeals dismissed the action. The Supreme Court affirmed, holding (1) res judicata barred Appellant’s habeas corpus petition because Appellant had filed at least one previous petition for habeas corpus; and (2) Appellant had an adequate remedy in the ordinary course of the law. View "Bevins v. Richard" on Justia Law

In 2005, Petitioner was convicted of first-degree-felony aggravated burglary and sentenced to six years in prison. After Petitioner was released an placed on postrelease control, he was found guilty of violating the conditions of his release and sentenced to a 150-day prison term. Petitioner subsequently filed a petition for writ of habeas corpus. The court of appeals dismissed the petition sua sponte for failure to comply with the requirement that Petitioner file a copy of his commitment papers with his petition. Petitioner appealed. Thereafter, Petitioner was released from prison under supervision. The Supreme Court affirmed the dismissal by the court of appeals, holding that, because Petitioner was no longer incarcerated, his petition was moot. View "Holloman v. Mohr" on Justia Law

In 1989, Petitioner, a prisoner at Grafton Correction Institution, was convicted of aggravated murder and other crimes. After a hearing in 2005, the parole board denied Petitioner parole. The board later determined that it should not have held the parole hearing because Petitioner had not yet served his minimum sentence at that time. Therefore, the board vacated its 2005 decision and continued Petitioner’s parole eligibility to 2015. In 2014, Petitioner filed this original action against the warden, claiming that the parole board violated his due process rights by vacating its 2005 decision. The warden filed a motion for summary judgment under Ohio R. Civ. P. 56(C). The court of appeals granted the motion for summary judgment. The Supreme Court affirmed, holding that the court of appeals (1) did not err by ruling on Petitioner’s motion for summary judgment under the Rules of Civil Procedure; and (2) properly granted summary judgment to the warden based on res judicata, as a habeas corpus action filed by Petitioner in 2013 was virtually identical to the complaint in this case. View "Brooks v. Kelly" on Justia Law

In 1986, Appellant was convicted of several sex-related crimes. Appellant was classified as a sexually oriented offender when Megan’s Law was enacted. In 2007, after Appellant was released on parole, he was convicted of failure to verify. In 2008, after Ohio enacted the Adam Walsh Act, Appellant was reclassified as a Tier III offender and convicted of failure to notify under the Act. In 2012, Appellant filed motions for de novo resentencing in the 2007 and 2008 cases, arguing that portions of the Adam Walsh Act were held unconstitutional in State v. Bodyke and thus that he had improperly been reclassified. Judge Frances McGee denied both motions. In 2013, Appellant filed this action seeking writs of mandamus and procedendo, asserting that the Judge McGee must vacate his conviction in the 2008 case, reclassify him, and reinstate the community-control sanctions imposed in the 2007 case. The court of appeals dismissed the action. The Supreme Court affirmed the dismissal of Appellant’s petition for writs of procedendo and mandamus because Appellant had an adequate remedy in the ordinary course of the law. View "State ex rel. Smith v. McGee" on Justia Law

Appellee was found guilty of murder and sentenced to death. The Supreme Court reversed. After a retrial, Defendant was convicted of aggravated murder and sentenced to death. The court of appeals affirmed the conviction and death sentence. After a “long and complex history,” a federal district court ultimately granted a writ of habeas corpus, finding that Appellee was denied the right to due process as interpreted in Brady v. Maryland. New proceedings subsequently commenced in the trial court. The trial court granted Appellee’s motion to dismiss, concluding that because of the prejudice suffered by Appellee in light of the State’s “egregious prosecutorial misconduct” and the Brady violations in his two prior trials, Appellee could not receive the fair trial he was entitled to. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court acted unreasonably, unconscionably, and arbitrarily when it found that it was impossible for Appellee to receive a fair trial without first giving the parties an opportunity to develop the record. Remanded to the trial court with instructions to proceed to trial. View "State v. Keenan" on Justia Law

In two separate cases, Defendant pleaded guilty to several counts of receiving stolen property. Defendant appealed, arguing for the first time that some of his convictions should have been merged for sentencing. The appellate court concluded that the trial court had committed plain error by failing to inquire into or address the question of whether the trial court erred in imposing sentences for allied offenses of similar import. Specifically, the court of appeals concluded that a trial court has a duty to inquire about allied offenses if the defense fails to raise it at sentencing. The Supreme Court reversed, holding (1) a defendant’s failure to raise the issue of allied offenses of similar import in the trial court forfeits all but plain error; (2) unless a defendant shows a reasonable probability that the convictions are for allied offenses of similar import committed with the same conduct and without a separate animus, he cannot demonstrate that the trial court’s failure to inquire whether the convictions merge for purposes of sentencing was plain error; and (3) because Defendant failed to object to his sentences in the trial court, he forfeited appellate review of the argument that he had been sentenced for allied offenses of similar import, and Defendant’s claim that the trial court committed plain error failed. View "State v. Rogers" on Justia Law

Defendant was stopped by a Lake Township patrol officer and canine handler for a marked lane violation on an interstate highway. The officer walked her dog around the vehicle Defendant was driving, leading to the discovery oxycodone tablets and a baggie of marijuana. It is undisputed that the township police officer exercised law-enforcement powers not granted to township police officers. Defendant moved to suppress the evidence obtained from the traffic stop, but the court denied it, concluding that the officer had probable cause to stop Defendant for a marked lane violation. Defendant was subsequently convicted. Defendant appealed, asserting that the officer lacked statutory authority to stop him for a marked lane violation on an interstate highway, and therefore, the stop and subsequent arrest and search were unconstitutional. The appellate court reversed Defendant’s conviction, concluding that the stop violated the Ohio Constitution because the marked lane violation occurred outside the officer’s territorial jurisdiction. The Supreme Court affirmed, holding that because the officer acted without authority to stop Defendant for a minor misdemeanor traffic offense on an interstate highway, the traffic stop, the arrest, and the search were unreasonable and violated Ohio Const. art. I, 14. View "State v. Brown" on Justia Law