Justia Ohio Supreme Court Opinion Summaries

Appellant appealed his conviction for two felonies. The court of appeals ordered Appellant to show cause why his appeal should not be dismissed for lack of a final, appealable order. Appellant subsequently returned to the trial court and moved for a revised termination entry. Judge Wiseman of that court entered a nunc pro tunc entry correcting the original judgment of conviction. The court of appeals affirmed Appellant's conviction, concluding that the error was cured by the nunc pro tunc entry, proceeded with the appeal. Thereafter, Appellant filed this action for writ of mandamus, contending that Judge Wiseman did not have the authority to sign the nunc pro tunc entry. The court of appeals dismissed the action, finding that the original judgment entry was a final, appealable order, as corrected by the nunc pro tunc order. The Supreme Court affirmed, holding that because Appellant had an adequate remedy at law, he was not entitled to the writ. View "State ex rel. Priest v. Dankof" on Justia Law

After a jury trial, Defendant was convicted of aggravated murder, aggravated robbery, and having weapons under disability. Prior to trial, Defendant filed a suggestion of incompetence to stand trial and a plea of not guilty by reason of insanity. A psychologist conducted a court-ordered evaluation on the issues of Defendant’s competency and sanity. Defendant later withdrew the defenses. On appeal, Defendant argued that the trial court violated his Fifth Amendment privilege against self-incrimination when it allowed the psychologist to testify during trial. The court of appeals reversed Defendant’s convictions for aggravated murder and aggravated robbery, concluding that Ohio Rev. Code 2945.371(J) prohibits the use of statements made by a defendant in a psychiatric evaluation against the defendant on the issue of guilt in a criminal action. The Supreme Court affirmed, holding (1) when a defendant asserts a mental-capacity defense, resulting in the court ordering a psychiatric evaluation, but then the defendant wholly abandons the defense, a psychologist’s testimony regarding the defendant’s feigning of mental illness during the court-ordered evaluation is inadmissible in the state’s case-in-chief pursuant to section 2945.371(J); and (2) the trial court’s admission of the psychologist’s testimony in this case was not harmless error. View "State v. Harris" on Justia Law

Following a jury trial, Defendant was convicted of the aggravated murders of his girlfriend and two children. The trial court sentenced Defendant to death. The Supreme Court affirmed. The Supreme Court affirmed the convictions and sentence of death, holding (1) the prosecutor did not violate Batson v. Kentucky during voir dire; (2) while the prosecutor made improper comments, the improper comments were not prejudicial and did not deny Defendant a fair trial; (3) the trial court did not err in admitting surveillance videos into evidence; (4) the evidence was sufficient to sustain Defendant’s convictions; (5) Defendant’s counsel did not provide ineffective assistance during either phase of trial; and (6) the death penalty was appropriate and proportionate when compared to death sentences approved in similar cases. View "State v. Pickens" on Justia Law

After a trial, Defendant was convicted of three counts of complicity to commit aggravated murder, two counts of attempted aggravated murder, and related crimes. After a mitigation hearing, the jury recommended death for the three aggravated murders. The trial court sentenced Defendant to death. The Supreme Court affirmed. Defendant filed a petition for postconviction relief, arguing that his trial counsel provided ineffective assistance by failing to conduct an adequate mitigation investigation prior to his mitigation hearing. The trial court denied Defendant’s petition for postconviction relief. The court of appeals vacated Defendant’s death sentence and ordered a new sentencing hearing, concluding that trial counsel’s decision to present only positive mitigation evidence was unreasonable, and undiscovered mitigating evidence might have influenced the jury’s appraisal of Defendant’s culpability. The Supreme Court affirmed, holding (1) trial counsel were deficient by failing to conduct a thorough and adequate investigation into Defendant’s background before his mitigation hearing; and (2) the court of appeals did not err in determining that counsel’s deficiency was prejudicial under Strickland. View "State v. Herring" on Justia Law

Mallon Roberts was found guilty of murder. On appeal, Roberts asserted that certain evidence should not have been allowed in the trial. After the conviction was affirmed, Roberts filed a motion for a new trial on the same basis. The trial court judge, Judge Melba Marsh, overruled the motion. Roberts then filed this action in the court of appeals asking that the court issue a writ of procedendo ordering Judge Marsh to rule on his motion. Specifically, Roberts contended that Judge Marsh’s ruling on his motion was not a proper ruling because it did not include required findings of fact and conclusions of law. The court of appeals dismissed the case. The Supreme Court affirmed, holding that Roberts had an adequate alternative remedy in the ordinary course of law, and because Judge Marsh had in fact ruled on the motion, Roberts was not entitled to a writ of procedendo. View "State ex rel. Roberts v. Marsh" on Justia Law

In 2004, Appellant was found guilty of several offenses. Appellant appealed and filed several other actions based on the judgment. Nearly a decade later, Appellant filed a complaint for writ of mandamus in the court of appeals, arguing that the original sentencing entry was never file-stamped and therefore was not a final, appealable order. Appellant sought to compel the Hamilton County Clerk of Courts to file-stamp the original sentencing entry. The court of appeals dismissed the action. The Supreme Court affirmed, holding that Appellant failed to show that the 2004 entry was not file-stamped and was not a final, appealable order. View "State ex rel. Smith v. Winkler" on Justia Law

Ohio Rev. Code 2929.20 provides that a prisoner cannot apply for judicial release until a period of time after the expiration of all mandatory prison terms in the stated prison sentence. Shawn Ware pleaded guilty to two counts of trafficking in crack cocaine. One count was a second-degree felony. Ware’s second-degree felony carried a mandatory prison term. The trial court imposed a four-year prison term for that offense. Ware later sought judicial release, arguing that he was eligible for release before the expiration of his four-year term because the original sentencing entry imposed only a minimum mandatory sentence of two years. The trial court granted the motion, explaining that it had not intended to make all four years of Ware’s sentence mandatory. The Supreme Court reversed, holding that Ware was not eligible for judicial release because his entire sentence was mandatory, and the trial court could not impose a different sentence under Ohio law. View "State v. Ware" on Justia Law

Cqualin Hawkins pleaded guilty to burglary, domestic violence, and assault. Hawkins was sentenced to four years on the burglary charge. Hawkins was later released on community control. While on community control, Hawkins was sentenced to three years for committing a new domestic violence offense. Because of the new crime, Hawkins’s community control release was evoked and his original sentence was reimposed. Hawkins filed this petition for writs of mandamus and habeas corpus asserting that the Ohio Department of Rehabilitation and Correction miscalculated his jail-time credit. The Supreme Court dismissed Hawkins’s habeas petition because it was moot, as Hawkins was no longer in custody at the time of this opinion, and dismissed Hawkins’s complaint for writ of mandamus because of flaws in the complaint. View "State ex rel. Hawkins v. Haas" on Justia Law

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