Justia Ohio Supreme Court Opinion Summaries

Appellant, an inmate at London Correctional Institution (LCI), made several public-records requests of LCI that were denied. While his last request was granted, Appellant filed an action in mandamus in the court of appeals to obtain the documents that he had not received. Appellant also sought statutory damages under Ohio Rev. Code 149.43. The court of appeals denied Appellant a writ and denied his claim for statutory damages. The Supreme Court reversed, granted a writ of mandamus, and awarded Appellant statutory damages and court costs because Appellant’s requests were not ambiguous, overbroad, or unduly burdensome and because Appellant complied with the requirements of section 149.43(C)(1). View "State ex rel. Carr v. London Corr. Inst." on Justia Law

Appellant was convicted and sentenced in the Cuyahoga County Court of Common Pleas. Appellant, who was incarcerated, filed a petition for a writ of habeas corpus alleging that the court in his criminal case lacked subject-matter jurisdiction because the indictment failed to establish that the crimes of which he was convicted occurred in Cuyahoga County. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that the court of appeals correctly dismissed Appellant’s petition based on its numerous procedural and other deficiencies. View "Arroyo v. Sloan" on Justia Law

While on parole, Appellant was convicted of three new offenses and sentenced to a new nine-year aggregate term. Appellant was incarcerated for the new offenses and became a member of the class of parolees entitled to a parole-revocation mitigation hearing under the consent decree upheld in Kellogg v. Shoemaker. Appellant, however, signed a Kellogg waiver. Appellant later filed a petition for a writ of habeas corpus arguing that his Kellogg waiver was invalid. The court of appeals dismissed the case because of procedural deficiencies in Appellant’s petition. The Supreme Court affirmed, holding that Appellant’s complaint was deficient and that the court of appeals was correct in dismissing his case. View "Al'Shahid v. Cook" on Justia Law

David Bundy served prison time before his conviction for failure to register as a sex offender was reversed. Bundy sought a declaratory judgment pursuant to Ohio Rev. Code 2743.48 that he had been wrongfully imprisoned for his failure to comply with the requirements of Ohio’s Adam Walsh Act (AWA) and that he was eligible to proceed for monetary relief against the State. The trial court found Bundy’s argument to be meritorious on the authority of three recent decisions from the Eighth District Court of Appeals, determining that the invalidation of certain provisions of the AWA on constitutional grounds required the conclusion that no violation had been committed and that Bundy, therefore, had the right to seek compensation under section 2743.48. The court of appeals affirmed. The Supreme Court reversed, holding (1) a claimant seeking a declaration that he is a wrongfully imprisoned individual does not satisfy the actual-innocence standard of section 2743.48(A)(5) by showing that his conviction was reversed solely because the statute describing the offense could not be enforced on constitutional grounds; and (2) therefore, Bundy was not entitled to seek compensation from the state. View "Bundy v. State" on Justia Law

After a jury trial, Appellant was found guilty of kidnapping and rape, both first-degree felonies. The trial court sentenced Defendant to a term of incarceration and ordered that Appellant have no contact with the victim. The court of appeals affirmed Appellant’s sentences, holding that “a trial court may impose a no contact order as part of its sentence.” The Supreme Court reversed the court of appeals and vacated the no-contact order, holding that a court cannot impose a prison term and a community-control sanction for the same offense, and no exception allows otherwise. View "State v. Anderson" on Justia Law

Appellant was convicted of murder, sexual battery, and other offenses and was sentenced to fifteen years to life. Appellant filed an action in habeas corpus seeking an order to compel Judge Joseph Russo to order his release from prison and asserting that a sex-offender-classification hearing was pending before Judge Russo and that the hearing was in violation of his plea agreement. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that the petition was correctly dismissed based on its numerous procedural defaults and because Appellant had an adequate alternate remedy at law. View "Pointer v. Russo" on Justia Law

In 1992, Appellant was found guilty of felonious sexual penetration. The conviction was affirmed on appeal. Thereafter, Appellant filed several postconviction motions that were denied. In 2014, Appellant filed an original action in procedendo in the court of appeals contending that that trial judge had failed to rule on a motion Appellant filed in 2013 to vacate a void judgment. Appellant also requested a writ of mandamus asking that the trial court correct a number of alleged errors in the trial proceedings. The court of appeals dismissed the petition for writs of mandamus and procedendo. The Supreme court affirmed, holding (1) the arguments raised by Appellant in support of his petition for a writ of mandamus related to issues that he could have raised on appeal, thus precluding a writ of mandamus; and (2) because the trial judge had ruled on Appellant’s motion to vacate a void judgment, the procedendo claim was properly dismissed. View "Shoop v. State" on Justia Law

Appellant was a state prisoner serving several sentences for multiple felony convictions. Appellant filed a petition for a writ of habeas corpus in the Court of Appeals. Appellant attached his judgment of conviction and sentencing entry for one case to his complaint but failed to attach any documents from a second case, which was pertinent to his entitlement to a writ of habeas corpus. The Court of Appeals dismissed the habeas petition on the grounds that it was procedurally defective. The Supreme Court affirmed, holding that Appellant’s failure to include all commitment papers with his complaint, where his maximum sentence had not been served, was fatal to his complaint. View "Pence v. Bunting" on Justia Law

After a jury trial, Appellant was found guilty of aggravated murder, rape, and aggravated burglary. The trial court sentenced Appellant to death. Appellant’s conviction and sentence were affirmed on direct appeal. Appellant later filed a motion for a new trial based on newly discovered DNA evidence. The trial court reduced Appellant’s conviction for rape to attempted rape and granted Appellant’s new trial motion as to the penalty phase. The trial court held that it had the authority to hold a resentencing hearing under Ohio Rev. Code 2929.06(B), which allows for the reimposition of the death penalty. Appellant filed a complaint for a writ of prohibition against the trial judge to prohibit the trial court from holding a resentencing hearing under section 2929.06(B). The Court of Appeals dismissed the complaint. The Supreme Court affirmed, holding that Appellant failed to demonstrate that the trial court patently and unambiguously lacked jurisdiction to hold a capital resentencing hearing under section 2929.06(B). View "State ex rel. Steffen v. Myers" on Justia Law

After a jury trial, Defendant was found guilty of two counts of retaliation, criminal damaging, vandalism, criminal trespass, possessing criminal tools, and ten counts of pandering. Defendant appealed, arguing that the trial court erred in denying his motion to suppress information found on his computer. The court of appeals affirmed, concluding that the affidavit provided a substantial basis for concluding that evidence of criminal activity would be found there. The Supreme court reversed, holding (1) the search warrant was not supported not supported by probable cause, and (2) the search warrant violated the Fourth Amendment requirement of particularity, thereby rendering invalid the search of Defendant’s computer. View "State v. Castagnola" on Justia Law