Justia Ohio Supreme Court Opinion Summaries

Defendant was convicted of two counts of rape of his minor stepdaughter. The Supreme Court reversed and remanded to the court of appeals to consider whether the trial court abused its discretion in admitting other-acts evidence under Ohio R. Evid. 404(B) during trial. On remand, the court of appeals vacated Defendant’s conviction and ordered a new trial, concluding that the trial court abused its discretion in admitting the other-acts evidence. The Supreme Court affirmed, holding (1) in determining the erroneous admission of evidence under Rule 404(B) is harmless error, an appellate court must consider both the impact of the offending evidence on the verdict and the strength of the remaining evidence after the tainted evidence is removed from the record; and (2) the court of appeals in this case did not err in finding that the Rule 404(B) evidence was improperly admitted at trial and in granting a new trial. View "State v. Morris" on Justia Law

In 2008, A police detective placed a global-positioning-system (GPS) tracking device on Defendant’s vehicle without obtaining a search warrant. Based on information gathered using the GPS device, law enforcement officers indicted Defendant for drug-related charges. Defendant moved to suppress the evidence, arguing that the warrantless placement and monitoring of the GPS tracking device on his vehicle violated his Fourth Amendment rights. The trial court denied the motion to suppress. The Supreme Court remanded to the trial court for application of United States v. Jones, decided in 2012, which held that attaching a GPS tracking device to an individual’s vehicle is a search within the meaning of the Fourth Amendment. On remand, the trial court found that placing the GPS device on Defendant’s van violated the Fourth Amendment but that the good-faith exception to the exclusionary rule applied. The Supreme Court affirmed, holding because binding appellate precedent justified placing GPS tracking devices on suspects’ vehicles without obtaining a search warrant at the time of the facts giving rise to this case, the good-faith exception to the exclusionary rule applied and exclusion of the evidence obtained by police in this case was not warranted. View "State v. Johnson" on Justia Law

In 2008, Michael Slager was sentenced for two separate offenses. In 2012 and 2013, Slager filed two complaints for a writ of mandamus in the court of appeals, arguing that he was entitled to additional jail-time credit. Slager subsequently filed motions to voluntarily dismiss and withdraw the actions, which the court of appeals granted. Later in 2013, Slager filed the present case in the Supreme Court seeking a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction and the Bureau of Sentence Computation to grant him additional jail-time credit. The Supreme Court dismissed the cause, holding that Slager’s dismissal in his second case operated as an adjudication upon the merits of his claim to extra jail-time credit and was thus res judicata. View "State ex rel. Slager v. Ohio Dep't of Rehab. & Corr." on Justia Law

After a jury trial, Appellant was convicted of attempted felony murder, felonious assault, and possessing a firearm while under a disability. At issue on appeal was whether a defendant can be convicted of attempted felony murder when there was no resultant death. The court of appeals reversed the conviction for attempted felony murder, concluding that attempted felony murder is not a viable criminal offense under Ohio law. The Supreme Court affirmed, holding that the court of appeals correctly determined that a person cannot be guilty of attempting to purposely or knowingly cause an unintended death, and therefore, attempted felony murder is not a cognizable crime in Ohio. View "State v. Nolan" on Justia Law

In 1998, Appellant was found guilty of two counts of aggravated murder and other offenses. Postrelease control was not specifically imposed at the sentencing hearing or in the sentencing entry. Appellant’s convictions were affirmed on appeal. In 2011, Appellant filed a complaint for a writ of procedendo asking the court of appeals to compel the trial judge to resentence him based on the improper imposition of postrelease control at sentencing. The court of appeals dismissed the complaint, concluding that Appellant had an adequate remedy by way of appeal to raise the postrelease-control issue. Nevertheless, the trial court subsequently imposed postrelease control for two of Defendant’s convictions. The court of appeals reversed and remanded. On remand, the trial court vacated the order imposing postrelease control. In 2013, Appellant filed a second complaint for a writ of procedendo arguing that his original sentencing entry was void because postrelease control had not been imposed. The court of appeals denied the petition. The Supreme Court, holding that the petition for a writ of procedendo was barred by res judicata, the case was moot, and Appellant’s arguments were wrong on the merits. View "State ex rel. Gregley v. Friedman" on Justia Law

Defendant was arrested pursuant to three misdemeanor arrest warrants. Based on information collected upon the execution of the arrest warrants, Defendant was charged with aggravated murder and aggravated robbery. Defendant filed a motion to suppress all evidence collected as a result of his arrest, contending that the arresting officers lacked a valid warrant to arrest him because no probable-cause determination was made before the warrants were issued and because the criminal complaints on which the warrants were based contained no information that would support a finding of probable cause. The trial court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the lower courts correctly determined that the warrants were issued improperly because there was no determination of probable cause; and (2) the remedy of suppression of the evidence obtained pursuant to the defective warrants was not available because the officers relied in good faith upon a procedure established in binding precedent. View "State v. Hoffman" on Justia Law

After a jury trial, Appellee was convicted of, inter alia, engaging in a pattern of corrupt activity. Appellee’s convictions were affirmed on appeal. The court of appeals reversed the conviction for engaging in a pattern of corrupt activity, concluding that Appellee’s appellate counsel had been ineffective for failing to challenge the jury instructions defining the term “enterprise,” as the jury instructions had been inadequate. The Supreme Court reversed, holding that the jury instructions, when read and understood together, adequately conveyed the law regarding the term “enterprise” and that the jury was appropriately and adequately informed on the issue. View "State v. Griffin" on Justia Law

In 1994, Appellant was convicted of several offenses associated with a robbery spree through Ohio and Michigan. In 2013, Appellant filed a petition for habeas corpus, arguing that because he was transferred to Michigan on a detainer to serve his sentence there, Ohio lost jurisdiction over him. The court of appeals dismissed the petition for failure to state a claim upon which relief can be granted, concluding that because Appellant had yet to serve his maximum Ohio term, which will expire in 2019, Appellant had failed to show that he was entitled to immediate release. The Supreme Court affirmed, holding that Appellant had not yet served his maximum twenty-five-year sentence sentence imposed in 1994, and therefore, habeas relief was not appropriate. View "State ex rel. Abercrombie v. Cuyahoga County Court of Common Pleas" on Justia Law

After a jury trial, Appellant was sentenced to death for the aggravated murder of a police officer. The Supreme Court affirmed Appellant’s convictions and sentence of death, holding (1) the trial court did not err by overruling Appellant’s objection to the State’s peremptory challenge, and the court conducted an adequate voir dire; (2) the trial court did not err by denying Appellant’s motion for a change of venue; (3) the trial court did not commit prejudicial error in its evidentiary rulings or in its instructions to the jury; (4) any questionable conduct that the prosecutor engaged in during the proceedings did not deprive Appellant of a fair trial; (5) Appellant’s counsel provided constitutionally effective assistance; and (6) Appellant’s challenges to the death penalty failed, and the death sentence was appropriate and proportionate in this case. View "State v. Thompson" on Justia Law

Appellee pleaded guilty to one count of theft and was sentenced to five years of community control and ordered to pay restitution to certain third parties. Appellee later applied to have the record of her theft conviction sealed. Although the trial court recognized that Appellee had not yet satisfied her obligation to make restitution to the third parties, it granted Appellee’s application to seal her record because Appellee had paid a substantial portion of the restitution owed. The court of appeals affirmed. The Supreme Court reversed, holding (1) a trial court may not seal an offender’s record before the offender has completed all sentencing requirements, including any order to make restitution to third parties; and (2) because Appellee still owed restitution in this case, she had not received a final discharge of her conviction and could not have her records sealed. Remanded tot he trial court with instructions to vacate its prior judgment. View "State v. Aguirre" on Justia Law