Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the court of appeals’ denial of Appellant’s petition for writs of mandamus and prohibition. In his original action for writs of mandamus and prohibition, Appellant alleged, among other things, that the judge who presided over his 1981 jury trial had never pronounced judgment or sentenced him. The court of appeals granted summary judgment for Defendants and denied the requested writs. The Supreme Court affirmed, holding (1) with one possible exception, the claims Appellant was making were barred by res judicata; and (2) summary judgment was proper on the only allegation that Appellant raised in the present case that may not have already been litigated. View "State ex rel. Jackson v. Ambrose" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing the petition of Appellant for a writ of mandamus. In his petition, Appellant argued that he was entitled to be released from custody under the same terms as his original parole because the Ohio Adult Parole Authority (APA) failed to hold a hearing within a reasonable time to determine whether Appellant had violated the terms of his release. The court of appeals granted summary judgment for the APA. The Supreme Court affirmed, holding (1) the court of appeals correctly ruled that Appellant’s mandamus claim was barred by res judicata because it arose “from a nucleus of facts that was the subject matter” of previous legal actions; and (2) the motion for declaratory judgment that Appellant filed in this appeal is denied. View "State ex rel. Alford v. Adult Parole Authority" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant’s petition for a writ of mandamus. Appellant was convicted of murder and sentenced to an indefinite term of a minimum of fifteen years to life, to be served consecutively to the sentence he was then serving on federal charges. Appellant later filed this action against the Bureau of Sentence Computation (BSC) requesting a writ of mandamus to compel BSC to calculate his term served under his state sentence as if the sentence were being served concurrently with, and not consecutively to, the federal sentence. The court of appeals dismissed the action. The Supreme Court affirmed, holding that Appellant’s arguments on appeal were unavailing. View "State ex rel. Sanford v. Bureau of Sentence Computation" on Justia Law

The Supreme Court denied Petitioner’s petition for a writ of habeas corpus seeking an order releasing him on bond and suspending execution of his sentence pending appeal. Petitioner, who was convicted of aggravated possession of drugs, appealed, seeking the reversal of his conviction based on ineffective assistance of counsel. The trial court denied Petitioner’s motion for bail pending appeal, and the court of appeals denied a similar motion filed by Petitioner. The Supreme Court held that Petitioner failed to show that the court of appeals abused its discretion in denying Petitioner’s motion for bond pending appeal and thus denied his petition for a writ of habeas corpus and denied as moot his motion for an expedited ruling. View "Small v. Hooks" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting judgment in favor of Michael Clay in this action seeking a writ of mandamus to compel the release of autopsy records by the Cuyahoga County Medical Examiner’s Office’s (ME) under Ohio Rev. Code 313.10(C)(1). On appeal, the ME argued, among other things, that the court should use the in pari material rule of statutory construction in determining the meaning of section 313.10(C)(1), which governs access to records held by a coroner’s office. The Supreme Court disagreed, holding (1) the in pari material rule of statutory construction and the absurdity exception to the plain-language rule of statutory construction are not applicable to section 313.10(C)(1); and (2) because section 313.10(C)(1) is plain and unambiguous, it is applied as written. View "State ex rel. Clay v. Cuyahoga County Medical Examiner's Office" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant’s original action seeking a writ of mandamus to compel the Ohio Adult Parole Authority (APA) to conduct a new parole-revocation hearing. The court held that because Appellant failed to comply with the mandatory requirements of section 2969.25(A), the court of appeals correctly dismissed Appellant’s petition. In addition to affirming the dismissal of Appellant’s original action, the court denied the APA’s motion to dismiss Appellant’s appeal, holding that the APA presented no basis for dismissal. View "State ex rel. Robinson v. Adult Parole Authority" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing the petition of Appellant for a writ of habeas corpus. Appellant was granted parole on the condition of “zero tolerance for any positive drug test.” The next month, he tested positive for drug use. After a revocation hearing, Appellant was reincarcerated. Appellant filed a petition for a writ of habeas corpus, claiming violations of his due process, equal protection, and confrontation rights. The court of appeals concluded that habeas corpus was not available to grant the relief Defendant sought. The Supreme Court agreed, holding that Defendant failed to state a proper claim in habeas corpus. View "State ex rel. Womack v. Sloan" on Justia Law

The Supreme Court vacated the decision of the Board of Tax Appeals (BTA) affirming the Franklin County Board of Revision’s (BOR) reduced valuation of a residential property in the amount of $65,000 for tax year 2011. The Franklin County auditor assigned a true value of $113,000 for tax year 2011. The owner filed a complaint seeking a reduction. The BOR reduced the property’s value to $65,000. The BTA upheld the BOR’s determination of value as sufficiently supported by the record. The Supreme Court remanded the matter to the BTA, holding that the BTA failed to evaluate independently the evidence to determine the value of the subject property. View "South-Western City School District Board of Education v. Franklin County Board of Revision" on Justia Law

The Supreme Court affirmed the Board of Tax Appeals’ (BTA) decision on remand adopting the appraisal valuation of the property owner’s appraiser for the second time. The property at issue was a vacant 22.27-acre parcel that the Delaware County auditor valued at $654,100 for tax year 2011. The property owner challenged the valuation and presented an appraisal determining a value of $580,000 for the property. The Delaware County Board of Revision (BOR) ordered a reduction to $580,000 after adopting the appraisal. The BTA affirmed the adoption of the appraisal. The Supreme Court issued a remand order based on the parties’ stipulation that the BTA should address certain issues. On remand, the BTA addressed those issues and again relied on the appraisal of the property owner’s appraiser. The Supreme Court affirmed, holding that the BTA acted reasonably and lawfully when it relied on the appraisal. View "Olentangy Local Schools Bd. of Education v. Delaware County Board of Revision" on Justia Law

The Supreme Court vacated the judgment of the Board of Tax Appeals (BTA) in this case disputing the valuation of real property retained by an owner after it sold a portion of its property during the tax year at issue and remanded the cause for the BTA to properly determine the value of the subject property. In 2009, the owner of the original parcel conveyed a single condominium unit for the Delaware County Board of County Commissioners for $2 million. For tax year 2009, the Delaware County auditor valued the conveyed parcel at $622,100 and the retained parcel at $1,677,900, for a total value of $2,300,000. The owner argued that the conveyed parcel’s 2009 value must be $2 million, leaving $300,000 as the value of its retained parcel. The Delaware County Board of Revision (BOR) agreed. The BTA reversed and reinstated the auditor’s valuation. The Supreme Court vacated the BTA’s decision, holding (1) the BTA’s finding that the sale was not recent to the tax-lien date was reasonable and lawful; but (2) the BTA improperly reinstated the auditor’s valuation because that valuation incorrectly apportioned 2.815 acres of condominium property to the retained parcel. View "Olentangy Local Schools Board of Education v. Delaware County Board of Revision" on Justia Law