Justia Ohio Supreme Court Opinion Summaries

Appellant was a political subdivision for purposes of the governmental-immunity provisions of Ohio Rev. Code 2744. Appellee sued Appellant, asserting several claims. Appellant filed a motion for partial summary judgment, claiming political-subdivision immunity. Appellant then unsuccessfully sought to file an amended answer raising political-subdivision immunity as an affirmative offense. Thereafter, the trial court granted summary judgment to Appellant on two of Appellee's claims. After Appellant appealed the trial court's denial of leave to file an amended answer, the case proceeded to trial. The jury returned a verdict in favor of Appellee on two of its remaining claims. Appellant filed a second appeal from the judgment. While Appellant's appeals were pending, the Supreme Court held that Appellant's first appeal divested the trial court of jurisdiction to proceed with a trial of any claim subject to the political-subdivision immunity defense. The court of appeals subsequently dismissed Appellant's appeals for lack of jurisdiction. The Supreme Court reversed, holding (1) the trial court's denial of Appellant's motion for leave to file an amended answer to raise the affirmative defense of political-subdivision immunity precluded Appellant from enjoying the benefits of the alleged immunity; and (2) the court of appeals therefore possessed jurisdiction to determine Appellant's appeal of that order. View "Supportive Solutions, LLC v. Elec. Classroom of Tomorrow" on Justia Law

Appellee was indicted on drug-related charges. The trial court granted Appellee's motion to suppress the evidence obtained during a search, finding the search violated the Fourth Amendment. A three-judge panel of the court of appeals affirmed. The State subsequently filed an application for en banc consideration and moved to have all eight judges of the court of appeals rule on its application. The three-judge panel that heard the State's original appeal denied the motion for participation of all eight judges and found that en banc consideration was unwarranted. At issue before the Supreme Court was whether it was proper for only the panel, and not the en banc court, to review and deny the State's application for en banc consideration. The Supreme Court affirmed, concluding that the court of appeals' method of handling the State's application for en banc consideration was permissible under Ohio R. App. P. 26(A)(2). View "State v. Forrest" on Justia Law

After a jury trial, Defendant was found guilty of sixty-eight counts, including one first-degree-felony count of engaging in a pattern of corrupt activity in violation of Ohio's Racketeer-Influenced and Corrupt Organizations (RICO) statute. Defendant was sentenced to a total prison term of sixteen years after the trial court determined that a mandatory ten-year prison term was required under Ohio Rev. Code 2929.14(D)(3)(a) for the corrupt-activity count. The court of appeals (1) affirmed the guilty verdicts for the corrupt-activity count and three of the predicate violations but reversed most of the remaining guilty verdicts; and (2) vacated the mandatory ten-year prison term imposed for the corrupt-activty count, finding section 2929.14(D)(3)(a) ambiguous as to whether the mandatory ten-year term applied to Defendant. The Supreme Court reversed, holding that a mandatory ten-year prison term is required pursuant to section 2929.14(D)(3)(a) if the court imposing a sentence for a felony finds the offender is guilty of corrupt activity with the most serious offense in the pattern of corrupt activity being a felony in the first degree. View "State v. Willan" on Justia Law

Employee was injured while in the course and scope of his employment. Employee's industrial claim was allowed for certain injuries. Fourteen years later, Employee successfully requested compensation for the total loss of the functional use of his right arm. Based on the Industrial Commission's award for loss of use, one year later Employee filed a motion for compensation for statutory permanent total disability. A staff hearing officer denied the application. The court of appeals granted Employee's writ of mandamus, concluding that the loss of use of Employee's arm could not be relitigated and that the Commission was bound by the doctrine of collateral estoppel to issue the award. The Supreme Court reversed the judgment of the court of appeals and denied the writ of mandamus, holding (1) the Commission must conduct an independent evaluation of the facts when considering an application for statutory permanent disability under Ohio Rev. Code 4123.58(C) even if a prior award for the same body parts has been given pursuant to Ohio Rev. Code 4123.57(b); and (2) the evidence in the record supported the basis for the Commission's decision. View "State ex rel. Coleman v. Indus. Comm'n of Ohio" on Justia Law

Employee was involved in a motor-vehilce accident while operating a one-ton dump truck within the course of his employment by Employer. Employee applied for and received benefits for his physical injuries. Employee subsequently requested an additional allowance for posttraumatic-stress disorder (PTSD) that arose contemporaneously as a result of the accident. The Bureau of Workers' Compensation (BWC) allowed Employee's additional claim. The trial court held that Employee's PTSD was not compensable because it did not arise from his physical injuries. The court of appeals affirmed. The Supreme Court affirmed, holding (1) for a claimant's PTSD to qualify as a compensable injury under Ohio Rev. Code 4123.01(C)(1), the claimant must establish his PTSD was causally related to his compensable physical injuries and not simply to his involvement in the accident; and (2) the court of appeals appropriately determined that the record contained competent, credible evidence supporting the trial court's finding that Employee's physical injuries did not cause his PTSD and that Employee's PTSD was, therefore, not a compensable injury under section 4123.01(C)(1). View "Armstrong v. John R. Jurgensen Co. " on Justia Law

Defendant pled no contest to domestic violence. Defendant was later indicted on three counts of felony abduction and one count of domestic violence stemming from the same incident. Defendant pleaded guilty to one count of abduction. The court of appeals reversed and vacated Defendant's guilty plea. On remand, the case went to trial, and a jury convicted Defendant of one count of abduction. Once again, the court of appeals reversed, and Defendant was ordered discharged. Defendant subsequently filed a complaint requesting that he be declared a wrongfully imprisoned person, a declaration required by statute before damages may be sought against the State. The trial court found that Defendant's prior guilty plea did not disqualify him from recovery under Ohio Rev. Code 2743.48 and declared Defendant a wrongfully imprisoned individual. The Supreme Court reversed, holding that a person who has pled guilty to an offense is not eligible to be declared a wrongfully imprisoned individual for that offense, even if the plea is later vacated on appeal. Remanded. View "Dunbar v. State" on Justia Law

Appellants were five upper-level employees of the Ohio Department of Natural Resource's Division of Wildlife (DOW). The Ohio inspector general (OIG) asked a deputy inspector to investigate alleged misconduct of a DOW wildlife officer. The inspector interviewed Appellants. The OIG's subsequent investigative report concluded that Appellants failed to report the wildlife officer's criminal conduct to the appropriate authorities. A grand jury later indicted each appellant on obstructing justice and complicity in obstructing justice. Appellants filed motions to suppress or, alternatively, dismiss, on the ground that their statements to the investigator were coerced by threat of job loss and were therefore inadmissible under Garrity v. New Jersey. The trial court suppressed Appellants' statements as compelled and therefore inadmissible under Garrity. The court of appeals reversed. The Supreme Court reversed, holding Appellants' statements during the OIG investigation required suppression because Appellants answered questions after receiving a warning that they could be fired for failing to do so, and statements extracted under these circumstances cannot be considered voluntary within the meaning of Garrity. View "State v. Graham" on Justia Law

After Countrywide Home Loans Servicing filed a complaint in foreclosure against Appellants, the trial court granted default judgment in favor of Countrywide, and the property was sold at a sheriff's sale. Countrywide subsequently filed a notice of voluntary dismissal and then refiled its complaint in foreclosure. The trial court granted the order of foreclosure, rejecting Appellants' claim that the action was precluded by res judicata. The appellate court affirmed, concluding that until the order confirming the sheriff's sale is entered, the plaintiff may terminate the case without prejudice by filing a notice of voluntary dismissal. The Supreme Court reversed, holding that a judgment of foreclosure cannot be dissolved by the filing of a notice of voluntary dismissal after a trial court has entered judgment on the underlying note. Remanded. View "Countrywide Home Loans Servicing, L.P. v. Nichpor" on Justia Law

Maria Marusa was driving her car when it was struck by a police cruiser driven by a police officer (Officer). Marusa and her daughter (collectively, Appellants) were injured in the accident. Appellants filed suit against Marusa's insurer (Insurer), seeking damages to compensate for medical expenses and pain and suffering. Insurer answered that it was not obligated to pay damages because even though the policy included uninsured-motorist coverage and the officer was an uninsured motorist, Appellants were not "legally entitled to recover" because Officer was immune under the Ohio Political Subdivision Tort Liability Law (OPSTLL). The trial court granted summary judgment for Insurer, and the court of appeals affirmed. The Supreme Court reversed, holding that the language of the policy unambiguously provides uninsured/underinsured motorist coverage when the insured is injured by an owner or operator who is immune under the OPSTLL. View "Marusa v. Erie Ins. Co." on Justia Law

Defendant was arrested and charged with operating a motor vehicle while under the influence of alcohol, speeding, and failing to reinstate his driver's license. Rather than participate in discovery pursuant to Ohio R. Crim. P. 16, Defendant submitted a public records request directly to the Highway Patrol. After the Highway Patrol provided Defendant with numerous records, the State successfully moved the trial court to compel Defendant to provide discovery, asserting that the public records request amounted to a demand for discovery and triggered a reciprocal duty of disclosure pursuant to Rule 16. The court of appeals reversed, holding that a public records request is not a demand for discovery, and therefore, Defendant owed no duty of reciprocal disclosure to the State. The Supreme Court reversed, holding (1) when an accused makes a public records request for information that could have been obtained from the State through discovery, that request is the equivalent of a demand for discovery, and a reciprocal duty of disclosure arises in accordance with Rule 16; and (2) because Defendant received evidence from the Highway Patrol that could have been obtained from the prosecutor through discovery, he had a reciprocal duty to provide discovery to the State. View "State v. Athon" on Justia Law