Justia Ohio Supreme Court Opinion Summaries

In 2008, Appellant was sentenced after pleading guilty to sixteen counts of breaking and entering and one count of engaging in a pattern of corrupt activity. The 2008 sentencing order was superseded by two subsequent orders, including a resentencing order. In 2013, Appellant filed an original action seeking a writ of mandamus compelling the common pleas court judge to resentence him, arguing that his first sentencing order was void based on five defects. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant failed to establish any defect in his current sentence and therefore failed to show he had a legal right to a new sentencing hearing. View "State ex rel. Kirkpatrick v. Rice" on Justia Law

William Glick filed a class action suit against Raymond Wohl, in his official capacity of the clerk of the municipal court, among other defendants, seeking declaratory and equitable relief related to Glick's municipal court sentences he alleged to be void for imposing unlawfully excessive court costs. The common pleas court determined that Glick’s class action against Wohl was viable, declared that multiple costs assessed against Glick as part of his sentence were unlawful, and held that Glick and other class members who had been assessed unlawful costs were owed a refund. The court of appeals reversed, concluding that the class action was not viable, and remanded for entry of summary judgment in favor of Wohl. The Supreme Court affirmed, holding (1) the relief requested by Glick in his class action was in substance a request to vacate a portion of a judgment of the municipal court; and (2) because a court of common pleas has no power to vacate an order rendered by a municipal court, summary judgment should have been granted in favor of Wohl. Remanded. View "Lingo v. State" on Justia Law

After a jury trial, Appellant was convicted of a number of offenses, including two counts of aggravated murder with capital specifications. Appellant was sentenced to life imprisonment. Appellant subsequently filed several post-trial motions, including motions for resentencing and a new trial, to no avail. Thereafter, Appellant filed a petition for a writ of procedendo to order the judge of the county court of common pleas to resentence him and to issue a final, appealable sentencing order in his criminal case. The court of appeals dismissed the motion on the basis of res judicata. The Supreme Court affirmed, holding that Appellant was not entitled to a writ of procedendo because he raised these same issues before and had an adequate remedy by way of appeal in previous cases.View "State ex rel. Williams v. Hunter" on Justia Law

After a jury trial, Defendant was found guilty of the aggravated murder of Nichole McCorkle and sentenced to death. The Supreme Court affirmed the judgment of conviction and the sentence of death, holding, among other things, that (1) the trial court did not err in admitting the autopsy report on McCorkle and by allowing a medical examiner, who did not conduct the autopsy, to testify about the autopsy results because an autopsy report that is neither prepared for the primary purpose of accusing a targeted individual nor prepared for the primary purpose of providing evidence in a criminal trial is nontestimonial and its admission into evidence at trial as a business record does not violate a defendant’s Sixth Amendment confrontation rights; (2) trial counsel did not provide constitutionally ineffective assistance; and (3) the trial court did not err by failing to appoint a neurologist to develop mitigation.View "State v. Maxwell" on Justia Law

After a bench trial, Defendant was convicted of kidnapping, importuning, gross sexual imposition, and public indecency. Each count related to an incident with B.P., a fourteen-year-old female. The court of appeals reversed the judgment of the trial court and vacated all of Defendant’s convictions, sua sponte, determining that there was insufficient evidence to prove Defendant’s identity as the man who had committed the offenses against B.P. The Supreme Court reversed the court of appeals, holding that the evidence of Defendant’s identity was overwhelming, and because neither party argued otherwise, the appellate court improperly decided the case on the basis of the new, unbriefed issue. View "State v. Tate" on Justia Law

At issue in this case was whether the State must prove a culpable mental state with respect to the element of the offense of robbery contained in Ohio Rev. Code 2911.02(A)(3) that the offender did “[u]se or threaten the immediate use of force against another.” After a jury trial, Defendant was convicted of one count of robbery. Defendant appealed, arguing that the trial court erred by not instructing the jury that the State had to prove that he had recklessly used force while committing or attempting to commit theft. The court of appeals agreed with Defendant and reversed. The Supreme Court reversed, holding (1) Ohio Rev. Code 2901.21(B), the statute for determining whether an offense imposes strict liability or requires proof of recklessness, applies only when a mental state is not specified in a section defining an offense; (2) because section 2911.02 defines every robbery to include the culpable mental states of the predicate theft offense, section 2901.21(B) does not apply; and (3) therefore, the State need not prove a culpable mental state with respect to the force element in section 2911.02(A)(3). View "State v. Tolliver" on Justia Law

Defendant was convicted of three counts of aggravated murder and other felony offenses. The Supreme Court affirmed Defendant’s convictions and sentence of death, holding (1) even if the trial court overstepped its bounds in conducting an Adkins hearing, no prejudice occurred; (2) Defendant’s waiver of a jury trial was voluntary, knowing, and intelligent; (3) the prosecutor did not engage in misconduct; (4) Defendant’s counsel provided constitutionally effective assistance; (5) the three-judge panel did not violate Defendant’s constitutional rights by choosing to give certain mitigating evidence no weight and limited weight; and (6) Defendant’s remaining claims similarly failed. View "State v. Jackson" on Justia Law

Appellant, an inmate, filed a complaint in mandamus in the court of appeals seeking an order compelling the Director of Rehabilitation and Correction to hold an immediate hearing and grant Appellant release from incarceration. The court of appeals dismissed the complaint on the basis that Appellant failed to file with his complaint several of the documents required by Ohio 2969.25. The Supreme Court affirmed because failure to comply with the requirements of section 2969.25 requires dismissal of an inmate’s complaint, and Appellant’s belated attempt to cure the defects in his complaint was to no avail, as the documents required the statute must be filed with the complaint. View "State ex rel. Hall v. Mohr" on Justia Law

Petitioner, an inmate, filed a petition for a writ of habeas corpus challenging the calculation of his jail-time credit and contending that aggregation of his sentences constituted double jeopardy. The court of appeals dismissed Petitioner’s claims. The Supreme Court affirmed, holding (1) habeas corpus does not lie to challenge the calculation of jail-time credit when a petitioner has an adequate remedy by appeal to raise the issue; (2) double jeopardy claims are not cognizable in habeas corpus; and (3) because Petitioner was not entitled to immediate release he failed to state a claim in habeas. View "Johnson v. Crutchfield" on Justia Law

At issue in this appeal was whether a trial court must engage in judicial fact-finding prior to imposing consecutive sentences on an offender. In this case, Appellant was sentenced to consecutive sentences aggregating eight years and five months for convictions arising out of four instances in which Appellant took $117 in change from vending machines. On appeal, Appellant argued that the imposition of consecutive sentences was contrary to law because the trial court did not expressly make the findings mandated by Ohio Rev. Code 2929.14(C)(4) and did not provide reasons in support of those findings when imposing consecutive sentences. The Supreme Court vacated the sentence and remanded for resentencing, holding (1) a trial court is required to make the findings required by section 2929.14(C)(4) at the sentencing hearing and incorporate its findings into its sentencing entry, but the court has no obligation to state reasons to support its findings; and (2) the trial court in this case did not make all of the findings required by section 2929.14(C)(4) at the time it imposed consecutive sentences, and neither did it incorporate all of the necessary findings into its judgment entry. Remanded for resentencing. View "State v. Bonnell" on Justia Law