Justia Ohio Supreme Court Opinion Summaries

In 2009, Defendant pled guilty to burglary. The trial judge sentenced Defendant to five years of community control and warned him that a violation of community control would result in an eight-year prison sentence. In 2011, the judge found Defendant in violation of the terms of community control and ordered the sentence into execution. The next day, the judge issued a nunc pro tunc entry clarifying her intent to sentence Defendant to prison for eight years. Defendant later filed this action for a writ of mandamus, claiming he was entitled to a writ to compel the trial judge to place him on community control or repentance him because the nunc pro tunc sentencing order was invalid. The Supreme Court affirmed, holding that Defendant failed to demonstrate a legal right to a writ of mandamus. View "State ex rel. Davis v. Saffold" on Justia Law

In 1992, while he was still a minor, Appellant was adjudicated delinquent for committing the equivalent of an operating a motor vehicle while intoxicated (OVI) offense. Appellant was not represented by counsel during the adjudication. In 2011, Appellant was convicted of OVI offenses that became felonies under the enhancing provision of Ohio Rev. Code 4511.19(G)(1)(d). The State added Appellant’s juvenile OVI adjudication to his four prior adult convictions to reach the “five or more” offenses threshold required to enhance his sentence under section 4511.19(G)(1)(d). Appellant moved to suppress the evidence of his juvenile adjudication, arguing that the adjudication violated his constitutional right to counsel. The trial court overruled the motion to suppress. Appellant was subsequently convicted of two counts and used Appellant’s 1992 juvenile adjudication as an OVI enhancement tool. The Supreme Court reversed and remanded for resentencing, holding that an adjudication of delinquency may not be used to enhance the penalty for a later offense under section 4511.19(G)(1)(d) when the adjudication carried the possibility of confinement, the adjudication was uncounseled, and there was no effective waiver of the right to counsel. View "State v. Bode" on Justia Law

After a jury trial in 1983, Appellant was found guilty of aggravated murder, aggravated burglary, and other offenses. Appellant’s convictions and sentences were affirmed on direct appeal. In 2013, Appellant filed an original action in the court of appeals seeking a writ of mandamus compelling the State to repentance him, arguing that the Supreme Court’s decision in State v. Johnson entitled him to a do novo resentencing. The court of appeals dismissed the petition, concluding that Johnson does not apply retroactively and that claims of sentencing errors are not cognizable in extraordinary writ actions. The Supreme Court affirmed, holding that Appellant was not entitled to a writ of mandamus, as (1) Johnson does not apply retroactively; and (2) Appellant had adequate remedies in the ordinary course of law. View "State ex rel. Walker v. State" on Justia Law

After a jury trial, Defendant was convicted of sixty-eight counts, all stemming from Defendant’s business enterprises. As relevant to this case, the jury found Defendant guilty of engaging in a pattern of corrupt activity in violation of Ohio’s Racketeer Influenced and Corrupt Organizations (RICO) statute. Relying on Ohio Rev. Code.14(D)(3)(a), the trial court sentenced Defendant to a mandatory term of ten years on the RICO count. The court of appeals vacated the mandatory ten-year prison term imposed for the RICO count, declaring that section 2929.14(D)(3)(a) was ambiguous. The Supreme Court reversed in part, holding that section 2929.14(D)(3)(a) unambiguously applied to Defendant and that Defendant fell squarely within the scope of section 2929.14(D)(3)(a). After the U.S. Supreme Court decided Alleyne v. United States, Defendant petitioned for certiorari, arguing that Alleyne prohibited imposition of the mandatory ten-year prison term. The U.S. Supreme Court vacated the Ohio Supreme Court’s decision and remanded. The Supreme Court reinstated its prior judgment, holding that imposition of Ohio Rev. Code 2929.14(D)(3)(a)’s mandatory sentence did not offend Defendant’s constitutional rights under Alleyne, as imposition of the mandatory sentence occurred without any judicial fact-finding. View "State v. Willan" on Justia Law

After a jury trial, Appellant was convicted of sixteen criminal counts and sentenced to life in prison. The court of appeals affirmed. Several years later, Appellant filed a complaint for a writ of habeas corpus against Appellee, warden of the Southeastern Correctional Complex, alleging that his convictions were the result of prosecutorial misconduct and that the court that convicted him lacked jurisdiction over him because the statute of limitations had run when he was tried. The court of appeals dismissed the complaint because Appellant had an adequate remedy by way of appeal and because he had failed to comply with Ohio Rev. Code 2969.25(C)(1). The Supreme Court affirmed, as Appellant had alternate remedies at law, which precluded a writ of habeas corpus, and because Appellant failed to comply with section 2969.25(C)(1). View "Russell v. Duffey" on Justia Law

Appellant, an inmate at Lorain Correctional Institution, sent Appellee, the warden of the institution, a public-records request to copy and inspect the Ohio Department of Rehabilitation and Correction employee rules of conduct. Appellant asserted that the requests were ignored. Appellant subsequently petitioned the court of appeals for a writ of mandamus against Appellee. The court of appeals dismissed the claim, finding that Appellant had failed to comply with Ohio Rev. Code 2969.25(C). Appellant filed a Ohio R. Civ. P. 60(B) motion seeking leave to amend his complaint, which the court also denied. The Supreme Court affirmed, holding that the court of appeals did not err in (1) dismissing the complaint due to Appellant’s failure to comply with section 2969.25; and (2) denying Appellant’s Rule 60(B) motion, as the failure to comply with the mandatory requirements of section 2969.25(C) is not curable by subsequent amendment. View "State ex rel. Young v. Clipper" on Justia Law

Based on investigations by law enforcement officials, a grand jury returned an indictment against several individuals and companies alleging that they had used an Internet gambling system to conceal illegal gambling by presenting it as an Internet sweepstakes. The prosecuting attorney then mailed letters to Plaintiff and other proprietors of Internet sweepstakes cafes threatening criminal prosecution if they did not immediately cease to run the sweepstakes. Plaintiff filed this action seeking to prohibit the prosecuting attorney from enforcing gambling laws against it with respect to Internet sweepstakes. Plaintiff sought to compel discovery of information related to the ongoing criminal investigation. The trial court ordered the prosecuting attorney to produce the information. The prosecuting attorney filed an interlocutory appeal. The court of appeals balanced the competing interests of Plaintiff and the prosecuting attorney and affirmed in part and reversed in part, holding that certain information being sought was not protected by the law enforcement investigatory privilege. The Supreme Court affirmed, holding (1) the law enforcement investigatory privilege is not absolute; and (2) the balancing test the Court adopted in Henneman v. Toledo for weighing the interests of law enforcement in keeping the information confidential against the needs of a civil litigant who requests the information in discovery remains valid. View "J & C Marketing, LLC v. McGinty" on Justia Law

Charles Watkins, an inmate at North Central Correctional Complex, filed an original action in mandamus against the chief of the Adult Parole Authority and chair of the Parole Board (together, Appellees), arguing that Appellees failed to affirm him review of his parole. The court of appeals dismissed the complaint sua sponte because Watkins’s affidavit did not comply with Ohio Rev. Code 2969.25(A)(1). The Supreme Court affirmed, holding that the court of appeals did not err by dismissing Watkins’s complaint sua sponte because it did not comply with the statute. View "State ex rel. Watkins v. Andrews" on Justia Law

After a jury trial, Defendant was convicted of the rape of three women, along with three associated aggravated burglaries. Defendant appealed, arguing, among other things, that the trial court erred by failing to merge the three aggravated burglary counts into the corresponding rape counts. The district court affirmed the trial court on the nonsentencing issues but vacated the sentences for the aggravated burglary and rape counts, concluding that because the conduct relied upon to establish the rapes was the same conduct used to establish the physical-harm element of the aggravated burglaries, the offenses were allied and subject to merger. At issue on appeal was whether the offenses in question were allied offenses of similar or dissimilar import within the meaning of Ohio Rev. Code 2941.25. The Supreme Court reversed, holding (1) offenses with resulting harm that is separate and identifiable are offenses of dissimilar import; and (2) because the court of appeals in this case did not consider whether the import of the aggravated burglary and the import of the rape were similar or dissimilar in each of the three separate events, the cause must be remanded for consideration of these factors. View "State v. Ruff" on Justia Law

Defendant was convicted of robbery and sentenced to five years in prison and three years of postrelease control (“Sentencing Order 1”). The court of appeals vacated Sentencing Order 1 and remanded the cause for resentencing because, at the sentencing hearing, the trial court had failed to advise Defendant about the particulars of post release control. Upon resentencing, the trial court amended its sentencing entry (Sentencing Order 2), but the court of appeals remanded the case with instructions to clarify Sentencing Order 2. In response to the remand order, the trial court issued Sentencing Order 3. The court of appeals dismissed Defendant’s appeal for failure to file a transcript of the resentencing hearing. Defendant sought discretionary review in the Supreme Court, but his appeal was not accepted. Defendant later filed a petition for a writ of mandamus seeking a writ compelling the trial judge to repentance him de novo, which he claimed was required by the appellate court’s decision in his appeal from Sentencing Order 1. The court of appeals granted summary judgment in favor of the trial judge. The Supreme Court affirmed, holding that the court of appeals correctly declined to issue a writ of mandamus on the grounds that Defendant had an adequate remedy at law. View "State ex rel. Turner v. Corrigan" on Justia Law