Justia Ohio Supreme Court Opinion Summaries

Appellants, Donald and Tamara Troyer, filed a medical-malpractice complaint against Appellee, Leonard Janis. In response, Appellee filed a motion for summary judgment in which he alleged that the claims asserted against him in the complaint had already been filed and dismissed in a previous action and were now barred by the doctrine of res judicata. In support of his motion, Janis attached a copy of the complaint in the prior case, the trial court's decision granting his motion to dismiss for failure to file an affidavit of merit, and the court's judgment of entry. The trial court granted summary judgment for Janis, and the court of appeals affirmed. The Supreme Court reversed, holding that a dismissal of a complaint for failure to attach the affidavit of merit is an adjudication otherwise than on the merits and is a dismissal without prejudice by operation of law. Remanded. View "Troyer v. Janis" on Justia Law

Defendant Carl Morris was convicted by a jury of two counts of rape involving a minor. Defendant appealed, contending that the trial court abused its discretion when it admitted evidence of other acts to prove the character of a person in order to show that the person acted in conformity therewith, in violation of Ohio R. Evid. 404(B). A divided appellate court vacated the conviction, concluding that the trial court improperly admitted other-acts testimony, that the court's error was not harmless, and that the error materially prejudiced Defendant. The Supreme Court reversed, holding (1) an appellate court is to apply an abuse-of-discretion standard of review when considering an assignment of error that claims the trial court improperly admitted evidence of other acts to prove the character of a person in order to show action in conformity therewith, in violation of Rule 404(B); and (2) the appellate court erred when it applied a de novo standard of review to this matter. Remanded. View "State v. Morris" on Justia Law

At issue in this case was whether Hamilton Township, a limited-home-rule township, was authorized under Ohio law to impose its system of impact fees upon applicants for zoning certificates for new construction or redevelopment within its unincorporated areas. Appellants, several development companies, brought this action against Appellees, the Township and its trustees, seeking a declaratory judgment, injunctive relief, and damages, alleging that the impact fees were contrary to Ohio law and were unconstitutional. The trial court granted summary judgment for the Township, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the impact fees charged by the Township in this case constituted taxes; and (2) since those taxes were not authorized by general law, the Township was unauthorized to impose them pursuant to Ohio Rev. Code 504.04(A)(1). View "Drees Co. v. Hamilton Twp." on Justia Law

At issue in this appeal was whether a court should enforce several employees' noncompete agreement transfers by operation of law to the surviving company when the company that was the original party to the agreement merged with another company. Here the trial court concluded that the employees did not intend to make the noncompete agreements assignable to successors such as the surviving company. The court of appeals affirmed. The Supreme Court affirmed, holding that in this case, the language the agreement dictated that the surviving company could not enforce the agreement after the merger as if it had stepped into the shoes of the original company. View "Acordia of Ohio, LLC v. Fishel" on Justia Law

The Ohio Department of Health (ODH) issued several notices of violations of the Smoke Free Act to Appellants, a privately owned bar and its CEO. ODH subsequently filed a complaint seeking injunctive relief ordering Appellants to comply with the Smoke Free Act. Appellants filed a counterclaim for declaratory and injunctive relief against ODH and a cross-claim against the attorney general, alleging that the Smoke Free Act operated in violation of Appellants' constitutional rights, that the Act was invalid as applied to them, and that ODH engaged in rulemaking that exceeded its authority. The trial court held that ODH had exceeded its authority in implementing a policy of strict liability for violations of the Act by issuing fines regardless of whether Appellants were at fault and denied ODH's request for a permanent injunction. The court of appeals reversed and granted a permanent injunction to ODH. The Supreme Court affirmed, holding (1) because Appellants failed to exhaust their administrative remedies and could not use declaratory judgment to vacate final orders, the previous violations of the Act were res judicata; and (2) the Act was a valid exercise of the state's police power and did not amount to a regulatory taking. View "Wymsylo v. Bartec, Inc." on Justia Law

A jury found Defendant Donald Eafford guilty of permitting drug abuse and possession of cocaine. The court of appeals vacated Eafford's felony sentence for possession of cocaine and remanded for resentencing, holding that Eafford was convicted only of misdemeanor possession of drugs because the jury-verdict form did not state the degree of the offense or specify that Eafford had possessed cocaine. The Supreme Court reversed the court of appeals and reinstated the sentence, holding that the trial court did not plainly err in imposing sentence, as (1) the indictment charged Eafford with possession of cocaine, and the least degree of that offense is a felony of the fifth degree; (2) the evidence presented at trial proved Eafford possessed cocaine; (3) the trial court instructed the jury that it could find Eafford guilty only if it found the drug involved to be cocaine; and (4) the jury, which found Eafford guilty as charged in the indictment, thus found him guilty of possession of cocaine as a felony. . View "State v. Eafford" on Justia Law

Paula Eastley, as the administrator of the estate of her son, Steven Hieneman, filed an amended complaint against Dr. Paul Volkman and Tri-State Healthcare, LLC, the clinic where Volkman practiced, and Denise Huffman, doing business as Tri-State Health Care. The jury found that Volkman's medical malpractice and Huffman's negligence had proximately caused Hieneman's death, and the trial court entered judgment in Eastley's favor. The court of appeals affirmed. Although two of the three judges on the court found that based on an ordinary negligence theory, the jury's verdict was against the manifest weight of the evidence, a dissenting judge prevented a reversal by concluding that because Huffman had not renewed her motion for a directed verdict or filed a motion for new trial or for judgment notwithstanding the verdict, she had forfeited all but plain error review. The Supreme Court reversed, holding (1) when the evidence to be considered is in the court's record, motions are not required to challenge manifest weight of the evidence on appeal; and (2) in civil cases, the sufficiency of the evidence is quantitatively and qualitatively different from the weight of the evidence. Remanded for consideration of the issue based upon the appropriate standard. View "Eastley v. Volkman" on Justia Law

In this case the Supreme Court was asked to resolve a conflict between the second and seventh district courts of appeals concerning whether a certified police officer who was appointed chief of police in a township with less than 10,000 residents, a police department with less than ten officers, and no civil service commission had the automatic right upon termination to return to the position he held before his appointment as chief of police pursuant to Ohio Rev. Code 505.49. The trial court concluded that Plaintiff, a former chief of police, had no right to return to the position in the police department that he held before his police chief appointment. The court of appeals affirmed. The Supreme Court affirmed based upon its reading of section 505.49, holding that the former chief of police had no automatic right to return to a position that he held prior to appointment. View "Blair v. Sugarcreek Township Bd. of Trustees" on Justia Law

After Employee, an electrician, received a work-related injury, Employee sought additional workers' compensation benefits, alleging that Employer committed a violation of a specific safety requirement (VSSR), which proximately caused his industrial injury. The requirement in question directs employers to supply protective apparatus to employees working on specified electrical equipment. A staff hearing officer (SHO) for the Industrial Commission of Ohio granted Employee's VSSR application after finding that Employer had violated Ohio Adm. Code 4123:1-5-12(A). Employer filed a complaint in mandamus, alleging that the commission had abused its discretion in finding a VSSR. The court of appeals denied the writ. The Supreme Court affirmed, holding that Employer violated section 4123:1-5-12(A) because it did not supply Employee with protective equipment for the main breaker cabinet Employer worked on when he was injured. View "State ex rel. Glunt Indus., Inc. v. Indus. Comm'n" on Justia Law

These consolidated appeals stemmed from a general election on Issue 6 in Lake Township, Stark County, that approved expansion of the a police district to include all of Lake Township's unincorporated territory and levied a property tax for that purpose. The issue was approved by the voters. Subsequently, many of those who had voted in the election filed a petition contesting the election approving Issue 6 due to an error in ballot language and requesting that the election be set aside. The common pleas court entered a judgment granting the contest and setting aside the election result approving Issue 6, determining that the error in ballot language constituted an election irregularity and that the election irregularity made the election result on Issue 6 uncertain. The Supreme Court affirmed, holding (1) this case presented the extreme circumstances of a misstatement in ballot wording that understated a proposed tax levy by ten times less than the true amount to be collected, which misled the voters and affected the integrity of the election on Issue 6; and (2) based on the applicable law, the common pleas court did not err in granting the contest and setting aside the election. View "In re Election held on Stark County Issue Six" on Justia Law