Justia Ohio Supreme Court Opinion Summaries

A jury found Jack Carlisle guilty of kidnapping and gross sexual imposition (GSI) and sentenced him to three years' imprisonment for kidnapping and one year of imprisonment for GSI, to be served concurrently. The trial court later vacated Carlisle's sentence due to change of circumstances, namely the cost of Carlisle's dialysis, and imposed a sentence of five years of community control. The court of appeals reversed, concluding that the trial court lacked authority to modify Carlisle's sentence because his convictions had been affirmed on appeal. The Supreme Court affirmed but on different grounds, holding that the trial court in this case lacked the requisite authority to modify Carlisle's sentence, as absent statutory authority, a trial court is generally not empowered to modify a criminal sentence by reconsidering its own final judgment. Remanded. View "State v. Carlisle" on Justia Law

A three-judge panel convicted Lamont Hunter for the aggravated murder and rape of a three-year-old and child endangerment. The panel sentenced Hunter to death based on two death-penalty specifications: aggravated murder while committing or attempting to commit rape and aggravated murder of a child under the age of thirteen. The Supreme Court affirmed Hunter's convictions and sentence of death, holding (1) Hunter did not meet his burden of demonstrating that his counsel rendered ineffective assistance; (2) the trial court did not abuse its discretion in admitting evidence that Hunter had previously abused the child; (3) the panel did not create a miscarriage of justice in convicting Hunter of all counts and specifications; (4) the panel did not err in denying multiple defense motions; (5) the panel did not err in sentencing Hunter to consecutive sentences for his noncapital offenses in violation of his constitutional rights; and (6) the aggravating factors clearly outweighed any mitigating factors beyond a reasonable doubt, and the penalty imposed in this case was appropriate and proportionate when compared to death sentences approved for other rape-murders. View "State v. Hunter" on Justia Law

After Appellant Jermaine McKinney was convicted and sentenced in a criminal case, Appellant petitioned for writs of mandamus and procendendo to compel Appellee, a county court of common pleas judge, to issue a final, appealable order in his criminal case. The court of appeals dismissed the petition. The Supreme Court affirmed, holding (1) the judge's sentencing entry in the criminal case fully complied with Ohio. R. Crim. P. 32(C) by including the findings of the jury upon which Appellant's convictions were based, the sentence, the signature of the judge, and the clerk's time stamp; and (2) Appellant had an adequate remedy by appeal to raise the claim that the judge erred in his sentencing entry. View "State ex rel. McKinney v. McKay" on Justia Law

Appellant David Untied petitioned for a writ of prohibition to prevent the judge of the court of common pleas from proceeding with a hearing on an alleged violation of community control and a writ of mandamus to compel the court of common pleas clerk to date-stamp and time-stamp all documents filed with the court. The court of appeals held that Untied was not entitled to the requested extraordinary relief. The Supreme Court affirmed, holding (1) the judge was authorized to conduct proceedings on the alleged community-control violations even though they were conducted after the expiration of the term of community control because the notice of violations was filed before Untied's community control expired; and (2) the documents filed with the court were all stamped with the date of filing in accordance with the pertinent provisions. View "State ex rel. Untied v. Ellwood" on Justia Law

Anthony Belton was charged with aggravated murder with death-penalty specifications and aggravated robbery with firearm specifications. Belton filed a motion challenging the constitutionality of Ohio Rev. Code 2929.03 and Ohio R. Crim. P. 11(C)(3), claiming these provisions were unconstitutional because they precluded him from entering a guilty plea without waiving his right to a jury trial during the sentencing phase of his capital case. The common pleas court denied the motion and upheld the provisions as constitutional. Belton later filed a motion for leave to file a delayed appeal from the common pleas court's order. The court of appeals granted the motion. The State subsequently filed an action for a writ of prohibition to prevent the court of appeals from proceeding in Belton's delayed appeal and to compel dismissal of the appeal. The Supreme Court granted the writ, holding that the court of appeals patently and unambiguously lacked jurisdiction to proceed with the appeal when the order did not constitute a final, appealable order. View "State ex rel. Bates v. Court of Appeals " on Justia Law

Appellant Carlos Galloway filed requests for writs of mandamus and procedendo to compel Appellees, the county court of common pleas and its judge, to issue judgments in Appellant's criminal cases that complied with Ohio R. Crim. P. 32(C) and constituted final, appealable orders. The court of appeals denied Appellant's request. The Supreme Court affirmed, holding (1) the sentencing entries in Appellant's criminal cases fully complied with rule 32(C); (2) insofar as Appellant's claimed that one of his sentencing entries did not properly reflect the jury's verdict, he raised mere error and had an adequate remedy by appeal to raise the issue; and (3) any error regarding the imposition of court costs could be challenged by appeal. View "State ex rel. Galloway v. Lucas County Court of Common Pleas" on Justia Law

Attorney submitted attorney-fee applications to the attorney general, requesting $1,563 in attorney fees for representing Client in connection with Client's application for crime-victim reparations. The attorney general granted an award of $1,020 to Attorney. A court of claims panel of commissioners affirmed the award. The attorney general appealed, challenging the jurisdiction of the court of claims. A judge of the court of claims affirmed, concluding that the court of claims had jurisdiction to hear an appeal from the attorney general's award of attorney fees. The tenth district court of appeals issued writs of mandamus and prohibition (1) compelling the court of claims to vacate its decision and dismiss the appeal, and (2) prohibiting the court of claims from hearing similar appeals from decisions of the attorney general on attorney-fee applications in the future. The Supreme Court affirmed, holding that the court of claims lacked jurisdiction to consider appeals from decisions of the attorney general granting or denying payment of attorney fees for seeking reparations on behalf of a victim of crime. View "State ex rel. DeWine v. Court of Claims of Ohio " on Justia Law

After a jury trial, Appellant was found guilty of various crimes. The judgment entry of conviction did not set out whether the conviction was based upon a guilty or no-contest plea or upon a bench trial or jury trial. The cause was remanded for resentencing for other reasons. On remand, the judgment entry contained the same error. The trial court then sua sponte filed a nunc pro tunc judgment entry supplementing the wording of the original resentencing judgment entry. The appellate court sua sponte dismissed the appeal for lack of jurisdiction, finding no new or substantial right was affected by correction of the sentencing judgment. Appellant subsequently obtained a certification of a conflict of the decision in this case with that of State v. Lampkin. At issue on appeal was whether a nunc pro tunc judgment entry that is issued solely to correct a clerical omission in a prior final judgment entry constitutes a new final order from which a new appeal may be taken. The Supreme Court affirmed, holding that no new right of appeal is created by such an entry, and therefore, the entry in this case was not a final order from which an appeal could be taken. View "State v. Lester" on Justia Law

A jury convicted Roland Davis of aggravated murder, murder, kidnapping, aggravated burglary, and aggravated robbery. Davis was sentenced to death. The trial court dismissed Davis's petition for postconviction relief, and the court of appeals affirmed. Davis then filed a motion for a new trial based upon newly discovered evidence. The trial court denied the motion. The court of appeals affirmed, holding that the trial court did not err because the trial court lacked jurisdiction to act on a motion for a new trial. The Supreme Court reversed the appellate court, holding (1) a trial court has jurisdiction over a motion for a new trial based on newly discovered evidence when the specific issue has not been decided on direct appeal; and (2) an appellate court has jurisdiction, in a case in which a death penalty has been imposed, to consider the trial court's denial a motion for a new trial based on newly discovered evidence. View "State v. Davis" on Justia Law

Corey Hazel filed a writ of habeas corpus to compel his release from prison. With his petition, Hazel filed an affidavit of indigency and sought waiver of prepayment of the court's filing fees. The court of appeals dismissed the petition, holding that the petition was defective because Hazel failed to include in his affidavit of indigency a statement setting forth his balance in his inmate account for the preceding six months, as certified by the institutional cashier, in violation of Ohio Rev. Code 2969.25(C). The Supreme Court affirmed, holding the court of appeals did not err in finding the petition defective because (1) the petition was in violation of section 2969.25(C), (2) as Hazel could have raised his claims in a previous habeas corpus case, res judicata barred Hazel from filing a successive habeas corpus petition, and (3) as Hazel's petition did not state a facially valid habeas corpus claim, the appellate court's dismissal without prior notice was proper. View "Hazel v. Knab" on Justia Law