Justia Ohio Supreme Court Opinion Summaries

Appellant pled guilty to several felonies. On March 11, 2002, the common pleas court entered a judgment entry of sentence. Eleven years later, Appellant filed a petition for writs of mandamus and prohibition, arguing that the March 11, 2002 judgment entry was defective because it did not indicate the manner of his conviction. On April 18, 2013, the trial court issued a nunc pro tunc judgment entry of sentence, this time indicating the manner of conviction. Appellant filed an amended petition, arguing that the nunc pro tunc entry did not cure the defective March 11, 2002 judgment entry. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant’s challenge to the validity of the March 11, 2002 judgment entry had no merit because the entry contained all four of the required elements under Ohio R. Crim. P. 32(C). View "State ex rel. Snead v. Ferenc" on Justia Law

Defendant was convicted of aggravated murder and sentenced to life imprisonment in 1990. The court of appeals affirmed. In 2009, Defendant argued that a final, appealable order never issued because the trial court failed to include the court's guilt-phase findings in the original judgment entry of sentence in violation of State v. Baker, which was decided in 2008. The trial court subsequently filed a new judgment entry and again sentenced Defendant to life imprisonment. The court of appeals reversed, concluding that Defendant's original sentence was not a final, appealable order and that the appellate court lacked jurisdiction to hear Defendant's original appeal. The Supreme Court vacated the judgment of the court of appeals and remanded for application of State v. Ketterer. On remand, the court of appeals reimposed its original reversal and remand. The Supreme Court reversed without reaching the proposition of law regarding Ketterer, holding (1) res judicata bars relitigation of matters that were raised or could have been raised on direct appeal when a final, appealable order was issued in accordance with the law at the time; and (2) because the sentencing entry issued in 1990 was a final, appealable order, the 2009 resentencing entry issued pursuant to Baker was a nullity. View "State v. Griffin" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of sexually-related crimes arising from incidents involving underage boys, including rape and gross sexual imposition. Defendant appealed, arguing, among other things, that his confrontation rights were violated when he was not allowed to cross-examine Mark Losko with the Bureau of Criminal Identification and Investigation (BCI) because Losko was not called to testify at trial regarding the DNA profile he created for Defendant and the alleged victims. The court of appeals affirmed the judgment of the trial court, concluding that because Losko's report contained only raw data and because Kristen Slaper, a BCI forensic analyst, testified and was cross-examined regarding her own report linking Defendant to the incriminating DNA evidence, Defendant's Sixth Amendment rights had not been violated. The Supreme Court affirmed, holding (1) when a defendant has stipulated to the admissibility and content of a nontestifying analyst's scientific report, the testimony of a witness who relied on that report does not violate the defendant's right to confrontation; and (2) because Defendant stipulated to Losko's report, he waived any later Confrontation Clause challenge to the use of the report by other witnesses. View "State v. Keck" on Justia Law

Defendant was indicted on a single, third-degree-felony count of failure to comply with a order or signal of a police officer in violation of Ohio Rev. Code 2921.331(B) and (C)(5)(a)(ii). After a jury trial, the trial court convicted Defendant as charged and sentenced him to four years in prison. Defendant appealed, arguing that, pursuant to Ohio Rev. Code 2945.75, the verdict form at trial was deficient. The court of appeals affirmed. The Supreme Court reversed, holding that the jury verdict supported only a misdemeanor conviction where the verdict failed to set forth the degree of the offense and failed to set forth the elements that elevated Defendant's crime from a misdemeanor to a felony. Remanded. View "State v. McDonald" on Justia Law

After a jury trial, Appellant was convicted of aggravated arson and arson. The trial court sentenced Appellant to ten years imprisonment for aggravated arson and five years for arson, to be served consecutively. The trial court notified Appellant that a postrelease-control sanction would be imposed but failed to state the duration of the sanction and which conviction it was part of. After Appellant completed his prison term for aggravated arson and began serving his prison term for arson, the trial court imposed postrelease control related to Defendant's aggravated-arson offense. Appellant appealed the sentencing judgment, arguing that because he had served the prison sentence for his aggravated-arson offense, the trial court lacked jurisdiction to impose postrelease control related to that offense. The court of appeals affirmed, holding that a trial court may resentence a defendant in order to correctly impose postrelease control if the defendant is still serving a prison term for any of the other offenses included in the same judgment entry of sentence. The Supreme Court reversed, holding that when Defendant completed his prison term for aggravated arson, the trial court lost the authority to impose a postrelease-control sanction for that offense. View "State v. Holdcroft" on Justia Law

Appellant was convicted of one count each of possession of heroin, trafficking in heroin, and conspiracy. After a series of motions seeking resentencing, Appellant filed a motion to vacate a nunc pro tunc order that had corrected an error in a sentencing entry, claiming that the order was void. Judge Jody Luebbers did not rule on the motion, arguing that she was divested of jurisdiction to entertain Appellant's subsequent filings once she had corrected the erroneous sentencing entry on remand. Appellant subsequently filed this action in procedendo, which the court of appeals denied. The Supreme Court reversed and granted a writ of procedendo to compel Judge Luebbers to rule on Appellant's motions, holding that the judge had general jurisdiction in this case, and therefore, Appellant's action for the writ of procedendo had merit. View "State ex rel. Brown v. Luebbers" on Justia Law

Defendant was convicted of failure to comply with a police officer and obstruction of official business. The trial court imposed separate sentences for the two offenses. Defendant appealed, arguing that the offenses should have merged at sentencing as allied offenses of similar import under Ohio Rev. Code 2941.25. The appellate court remanded for a determination as to whether the offenses were allied offenses under State v. Johnson, which instructs courts that a defendant's conduct "must be considered" when determining whether multiple offenses merge at sentencing pursuant to section 2941.25. The trial court determined that the offenses were not allied offenses of similar import and imposed separate prison terms for the two offenses. The court of appeals reversed, concluding that Defendant's sentences merged under Johnson because they were based on the same conduct. The Supreme Court reversed, holding (1) when deciding whether to merge multiple offenses at sentencing pursuant to section 2941.25, a court must review the entire record to determine whether the offenses were committed separately or with a separate animus; and (2) the court of appeals erred by relying on Johnson for the proposition that a court may consider a defendant's conduct only as it was described by the state's theory at trial. View "State v. Washington" on Justia Law

As part of a negotiated agreement, Appellant pled guilty to robbery and was sentenced to six years' imprisonment. The sentencing court issued two nunc pro tunc orders to correct an error in the original sentencing entry. On appeal, Appellant argued, inter alia, that the sentencing court lacked the authority to issue the nunc pro tunc entries. The Supreme Court affirmed, holding that Appellant's claims were not cognizable in habeas corpus because (1) Appellant had an adequate remedy in the ordinary course of law; (2) sentencing orders are, in general, not cognizable in habeas corpus; and (3) a nunc pro tunc order correcting a clerical error in a sentencing entry is not unlawful. View "Daggett v. Bradshaw" on Justia Law

Ramona Whitley and Debra Jones, teachers at a preschool day care, questioned three-year-old L.P. about an eye injury and marks on his face upon his arrival at the preschool. Whitley reported suspected child abuse after L.P. identified Defendant as responsible for his injuries. A grand jury subsequently indicted Defendant of several counts of felonious assault, endangering children, and domestic violence. After a jury trial, Defendant was convicted of all charges except one felonious assault count. The court of appeals reversed Defendant's convictions and remanded for a new trial, holding that the trial court abused its discretion by permitting the preschool teachers to testify regarding L.P.'s statements in violation of the Confrontation Clause. The Supreme Court affirmed, holding (1) statements elicited from a child by a teacher in the absence of an ongoing emergency and for the primary purpose of gathering information of criminal conduct and identifying the alleged perpetrator of suspected child abuse are testimonial in nature; and (2) therefore, the admission of L.P.'s statements violated Defendant's right to confrontation. View "State v. Clark" on Justia Law

Petitioner pled guilty to various drug and weapons offenses and was sentenced to five years' imprisonment. On February 17, the trial court issued an order granting 1,530 days of jail-time credit. On February 18, however, the court set aside the February 17 entry on the grounds that it had been inadvertent. Petitioner was ultimately resentenced to concurrent five-year sentences for the remaining offenses with 964 days of jail-time credit. Petitioner subsequently made the February 17 and February 18 entries the subject of numerous proceedings, including a habeas action, in which he claimed that he was entitled to the jail-time credit awarded him in the February 17 entry. Petitioner then filed this petition for a writ of habeas corpus, making the same claim advanced in his earlier habeas petition. The Supreme Court dismissed the habeas action, holding (1) Petitioner had alternate remedies in the ordinary course of law to pursue relief on his claim; (2) res judicata barred Petitioner's claim; and (3) Petitioner's claim was invalid on the merits. View "Pruitt v. Cook" on Justia Law