Justia Ohio Supreme Court Opinion Summaries

Defendant was charged with, inter alia, operating a vehicle while intoxicated (OVI). Defendant filed a motion to suppress the evidence obtained during the traffic stop. The trial court denied the motion to suppress, concluding that the motion lacked sufficient particularity on the issue of alleged improper administration of field sobriety tests. At the pretrial conference, Defendant pled no contest. The trial court subsequently found Defendant guilty of OVI. The court of appeals affirmed the denial of Defendant’s motion to suppress, finding the motion deficient because more factual detail was needed. The Supreme Court reversed, holding that a highly detailed pleading of the facts and law is not required to satisfy the notice requirements of State v. Shindler and to trigger the right to a hearing on a motion to suppress.View "State v. Codeluppi" on Justia Law

Appellant was found guilty of four felonies, with forfeiture specifications, for running a marijuana-distribution operation out of a building he and his brothers owned on Scranton Road. Common Pleas Court Judge Nancy McDonnell issued a sentencing entry listing the property at Scranton Road as property to be forfeited. On October 11, 2011, Appellant appealed the sentencing order. On January 13, 2012, Judge McDonnell issued a journal entry reiterating Appellant’s sentence and ordering transfer of the property. On October 23, 2012, Appellant sought a writ of prohibition to vacate Judge McDonnell’s January 13, 2012 order, arguing that Judge McDonnell lacked jurisdiction to enter the order. The court of appeals dismissed Appellant’s petition, concluding that Ohio Rev. Code 2981.04 vested Judge McDonnell with jurisdiction to conduct forfeiture proceedings even after the notice of appeal was filed. The Supreme Court affirmed, holding that Judge McDonnell did not patently and unambiguously lack jurisdiction and that any errors in the proceedings should be addressed on appeal. View "State ex rel. West v. McDonnell" on Justia Law

Appellant was convicted of rape he committed in 1983. In 2009, while out of prison on parole, Appellant committed two theft offenses at a gas station. Appellant subsequently pled guilty to two misdemeanor offenses of petty theft, and the Ohio Adult Parole Authority (“OAPA”) found Appellant had violated the conditions of his parole. In 2011, Appellant filed an administrative grievance with the OAPA, contending that the 2009 report recommending revocation of his parole falsely stated that Appellant used a knife and committed rape during the offenses. The OAPA rejected the complaint. Appellant filed a petition for a writ of habeas corpus asking the court of appeals to compel with OAPA to expunge the false statement from the violation report and conduct a new parole hearing. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that because the statement at issue in the violation report was referring to the 1983 rape, not the 2009 incident, the statement in the report was factually accurate and Appellant’s rights were not violated.View "Scarberry v. Turner" on Justia Law

Appellant was indicted on one count of rape. After a jury trial, Appellant was found not guilty of rape and not guilty of sexual battery but guilty of the lesser included offense of gross sexual imposition. The court of appeals remanded the case, holding (1) the trial court did not abuse its discretion in instructing the jury on the lesser included offense of gross sexual imposition over Appellant’s objection; and (2) there was insufficient evidence to support a conviction for gross sexual imposition but that there was sufficient evidence to prove the lesser included offense of sexual imposition. Upon remand, the trial court found that Appellant was guilty of sexual imposition. Appellant appealed, arguing that, as a matter of trial strategy, a defendant has a right to present an “all or nothing defense” and refuse any lesser-included offenses instructions. The Supreme Court affirmed, holding that a defendant does not have such a trial, and the trial court, after reviewing the evidence, must give an instruction on a lesser included offense if its is possible for the trier of fact to find the defendant not guilty of the greater offense and guilty of the lesser offense. View "State v. Wine" on Justia Law

Appellant was convicted of two felony counts of operating a vehicle while intoxicated (OVI), each with a specification that he had been convicted of or pled guilty to five or more OVI violations or equivalent offenses within the previous twenty years. The convictions were affirmed on appeal. Appellant filed a complaint for writ of mandamus in the court of appeals naming the judge who had presided over his criminal trial as respondent, claiming that his conviction and sentence under the specification were void because the jury never found that he had been convicted of five felony OVI offenses. The court of appeals dismissed the motion, concluding that Appellant had adequate remedies at law to challenge his sentencing entry. The Supreme court affirmed, holding that Appellant had an adequate remedy at law by way of appeal, and even if the Court were to reach the merits, Appellant’s arguments were unavailing. View "State ex rel. Beechler v. Rastatter" on Justia Law

Appellant pled guilty to multiple criminal offenses, both state and federal. Appellant sought release from prison, arguing that the sentencing entry was ambiguous regarding whether his state sentences were to be served concurrently or consecutively to his federal sentence, and as a result, the sentences must be concurrent. The court of appeals dismissed Appellant’s petition for habeas corpus. The Supreme Court affirmed, holding (1) habeas corpus was inappropriate in this case because sentencing errors are not cognizable in habeas corpus; (2) the availability of other adequate remedies at law also precludes relief in habeas corpus; and (3) even if Appellant could overcome the problems with habeas in this case, his arguments were without merit because the sentencing entry was not ambiguous. View "State ex rel. O’'Neal v. Bunting" on Justia Law

In 1995, Todd Plassman pled guilty to several counts of rape. Plassman was sentenced to indefinite terms of nine to twenty-five years, to be served concurrently but consecutively to his sentence imposed in another case. Over the years, Plassman filed, unsuccessfully, a variety of actions attempting to enforce the alleged limit on his sentence. In this instant case, Plassman filed a petition for a writ of habeas corpus, asserting that the prosecutor and judge in his 1995 case agreed off the record that he would serve no more than a ten-year term of imprisonment if he pled guilty. The Supreme Court denied the writ, holding that the issues Plassman raised were not only res judicata but were barred from consideration in habeas corpus due to the availability of other remedies. View "Plassman v. Ohio Adult Parole Auth." on Justia Law

Defendant was a juvenile when he committed acts constituting aggravated robbery. After a mandatory bindover hearing, the juvenile court relinquished jurisdiction and transferred the matter to the common pleas court. Defendant did not object to the mandatory bindover. Defendant then pleaded guilty to one count of aggravated robbery with a firearm specification. Defendant was sentenced to four years in prison. Defendant appealed, arguing, for the first time, that the statutory mandatory bindover procedures violated his constitutional rights and that defense counsel provided ineffective assistance by failing to raise these claims in the lower courts. The court of appeals affirmed, holding that, by pleading guilty, Defendant had waived his right to challenge either the mandatory bindover or his attorney’s failure to object to it and that Defendant had not demonstrated that his counsel provided ineffective assistance. The Supreme Court affirmed, holding that Defendant forfeited his challenge to the constitutionality of the mandatory bindover statutes by failing to present it to the lower courts. View "State v. Quarterman" on Justia Law

After a jury trial, Defendant was found guilty of felonious assault and carrying a concealed weapon. The appellate court remanded the matter for resentencing, determining that the trial court did not properly impose postrelease control. At the resentencing hearing, Defendant told the trial court that he wanted to represent himself. Thereafter, the court announced that Defendant would be subject to mandatory postrelease control upon release from prison. Defendant appealed, arguing that his right to counsel was violated during the resentencing proceedings and that a resentencing hearing is a critical stage of a criminal proceeding to which the right to counsel attaches. The appellate court affirmed, holding that the trial court had not violated Defendant’s right to counsel by allowing him to represent himself at the resentencing hearing. The Supreme Court affirmed, holding (1) a resentencing hearing is a critical stage of the proceedings to which the right to counsel attaches; and (2) Defendant knowingly, intelligently, and voluntarily waived his right to counsel at the resentencing hearing. View "State v. Schleiger" on Justia Law

Defendant pled guilty to aggravated murder and related charges. A three-judge panel sentenced Defendant to death on the capital charge and to various prison terms for the noncapital offenses. The Supreme Court twice vacated the sentences and remanded for resentencing. After the three-judge panel issued a new sentencing entry, Defendant appealed, raising five propositions of law. The Supreme Court affirmed Defendant’s sentence, holding (1) discovery was not improperly denied following the second; (2) the panel did not impose consecutive terms of postrelease control; and (3) the remainder of Defendant’s arguments were barred by res judicata. View "State v. Ketterer" on Justia Law