Justia Ohio Supreme Court Opinion Summaries

After she was told in advance that her contract for employment would not be renewed, Stacey Carna, the principal of an elementary school, requested a meeting with the school board to discuss the nonrenewal of her contract. Without meeting with Carna, the board voted not to renew Carna's contract. The common pleas court denied Carna's subsequent request for mandamus relief, and the court of appeals affirmed. The Supreme Court reversed, holding that after an administrator has been informed that her contract will not be renewed, upon the administrator's request for a meeting with the school board to discuss the nonrenewal of her contract, Ohio Rev. Code 3319.02(D)(4) requires the board to meet in executive session with the administrator to discuss the reasons for nonrenewal. Remanded. View "State ex rel. Carna v. Teays Valley Local Sch. Dist. Bd. of Educ." on Justia Law

Kenneth Schwering and his wife were driving a Ford when they were involved in a traffic accident. Schwering's wife was killed and Schwering was injured. Both were wearing their seatbelts. Schwering filed a complaint against Ford Motor Company and TRW Safety Systems, asserting products-liability and negligence claims. After the case proceeded to a jury trial, the trial judge declared a mistrial. Before the second trial began, Schwering filed a notice of voluntary dismissal without prejudice pursuant to Ohio R. Civ. P. 41(A)(1)(a). Schwering subsequently filed a lawsuit in the U.S. district court, asserting the same claims against the same defendants. The defendants moved to dismiss the federal action, arguing that Schwering's voluntary dismissal of the state action did not occur "before the commencement of trial" as required by Rule Civ. R. 41(A)(1)(a), and thus the dismissal could not have been "without prejudice." The Supreme Court accepted certification from the U.S. district court and held that a plaintiff may not voluntarily dismiss a claim without prejudice pursuant to Rule 41(A)(1)(a) when a trial court declares a mistrial after the jury has been empaneled and trial has commenced. View "Schwering v. TRW Vehicle Safety Sys., Inc." on Justia Law

The trial court appointed a receiver for Sager Corporation for the purpose of accepting service of process and marshaling assets consisting of unexhausted liability-insurance policies for asbestos-related claims filed against Sager. Sager was an Illinois corporation that filed for dissolution in 1998 and, pursuant to Illinois law, was no longer amenable to suit after 2003. The appellate court affirmed. The Supreme Court reversed the judgment of the appellate court, holding that, in conformity with the constitutional requirements of due process and the Full Faith and Credit Clause, claims filed against the dissolved Illinois corporation more than five years after dissolution were barred, and therefore, the appointment of the receiver was barred. View "In re Sager Corp." on Justia Law

C.P. was fifteen years old when he was charged with two counts of rape and one count of kidnapping with sexual motivation. The juvenile court found C.P. to be a delinquent child and designated him a serious youthful offender in relation to each offense. Further, the court classified C.P. a public-registry-qualified juvenile-offender registrant (PRQJOR) and a Tier III sex-offender/child-victim offender pursuant to Ohio Rev. Code 2152.86. At issue on appeal was the constitutionality of section 2152.86, which created the new class of juvenile sex-offender registrants, PRQJORs, who are automatically subject to mandatory, lifetime sex-offender registration and notification requirements without the participation of a juvenile judge. The Supreme Court reversed, holding that to the extent that it imposes such requirements on juvenile offenders tried with the juvenile system, section 2152.86 violates the constitutional prohibition against cruel and unusual punishment and the due process clauses of the state and federal Constitutions. View "In re C.P." on Justia Law

Appellant Roland Nickleson filed a complaint for a writ of mandamus to compel Appellee, the county court of common pleas judge, to issue a final, appealable order in his criminal case. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding (1) notwithstanding Nickleson's claims, his sentencing entry was a final, appealable order because it contained a full resolution of all the counts of his indictment for which there were convictions; and (2) Nickleson had an adequate remedy by appeal from his sentencing entry to raise his other claims contesting the validity of the indictment, the propriety of the jury instructions, and the sufficiency of the evidence supporting his convictions. View "State ex rel. Nickleson v. Mayberry" on Justia Law

While receiving permanent total disability compensation, Appellant Donald McNea's was engaged in the illegal sale of narcotics. Appellee Industrial Commission of Ohio terminated McNea's benefits after finding that he had engaged in sustained remunerative employment while receiving those benefits. McNea filed a complaint in mandamus in the court of appeals. The court found no abuse of discretion had occurred and denied the writ. McNea appealed, challenging the Commission's finding that he was performing, or capable of performing, sustained remunerative work while receiving benefits, a determination that generated a declaration of overpayment for compensation paid during that period. The Supreme Court affirmed, holding that the Commission did not abuse its discretion in characterizing McNea's remunerative employment as sustained, and the Commission did not violate McNea's due process rights by terminating his benefits while he was in prison. View "State ex rel. McNea v. Indus. Comm'n" on Justia Law

Rick Warner was a construction worker who had periods of unemployment each year that were the result of seasonal layoffs. After being injured at work, Warner asked the Industrial Commission of Ohio to establish his average weekly wage (AWW) for the purpose of awarding future compensation. At issue was the treatment to be accorded those weeks of unemployment in calculating Warner's AWW. A commission staff hearing officer excluded from the wage total the amount of unemployment compensation received but included in the weekly divisor the number of weeks that Warner did not work. The court of appeals subsequently issued a limited writ of mandamus ordering the commission to further consider Warner's request. The Supreme Court (1) affirmed the court of appeals judgment ordering further consideration of the adequacy of Warner's job search, as, in setting the AWW, any period of unemployment due to causes beyond the employee's control shall be eliminated from the weekly divisor; and (2) reversed the portion of the court of appeals judgment ordering the commission to include the amount of Warner's unemployment compensation from his wage total. View "State ex rel. Warner v. Indus. Comm'n" on Justia Law

Defendant pled guilty to aggravated murder and kidnapping. At his sentencing hearing, Defendant was notified of postrelease control, but the language indicating notification had been made was inadvertently omitted from the sentencing entry that resulted from that hearing. When the omission came to light, the trial court corrected the sentencing entry through a nunc pro tunc entry that stated that the notification had been made and denied Defendant's request for a new sentencing hearing. The appellate court upheld the trial court's actions as a permissible use of a nunc pro tunc entry. The Supreme Court affirmed, holding that the trial court's use of a nun pro tunc entry was appropriate in the specific circumstances of this case. View "State v. Qualls" on Justia Law

Gerald Strothers requested that East Cleveland Mayor Gary Norton provide access to review, inspect, and copy at cost various public records. A week after Strothers's public-records request was received by Norton, Strothers filed a petition for a writ of mandamus to compel Norton to provide access to the requested records. Norton subsequently made available to Strothers all of the requested records. The court of appeals denied the writ of mandamus but awarded Strothers $1,000 in statutory damages. The Supreme Court affirmed the portion of the judgment denying the writ of mandamus and reversed the portion awarding statutory damages, holding that the court of appeals (1) correctly held that Norton's evidence established that Strothers had been given access to all of the requested records, which rendered his mandamus claim moot; and (2) abused its discretion in granting statutory damages to Strothers, as Norton produced the records within a reasonable period of time. View "Strothers v. Norton" on Justia Law

After receiving a dispatch that a male driving a tow truck was armed and planned to kill himself, two police officers stopped the driver, Richard Dunn. Because they were dealing with an allegedly suicidal person, they handcuffed Dunn and placed him in a police cruiser. The officers subsequently found a loaded gun in the truck's glove compartment. Dunn was indicted on one count of improper handling of a firearm in a motor vehicle. Dunn filed a motion to suppress, contending that the traffic stop violated the Fourth Amendment. The trial court overruled the motion, holding that the stop was a legitimate response to an emergency situation. Dunn then pleaded no contest to the charge. The court of appeals reversed and granted the motion to suppress. The Supreme Court reversed the court of appeals and reinstated the judgment of the trial court, holding that the officers in this case were authorized to stop Dunn because the community-caretaking/emergency-aid exception to the Fourth Amendment warrant requirement allows a low-enforcement officer with objectively reasonable grounds to believe that there is an immediate need for her assistance to protect life or prevent serious injury to effect a community-caretaking/emergency-aid stop. View "State v. Dunn" on Justia Law