Justia Ohio Supreme Court Opinion Summaries

At issue in this case was Ohio Rev. Code 4921.25, which grants the Public Utilities Commission of Ohio (PUCO) authority to regulate towing companies as “for-hire motor carriers.” The City of Cleveland filed an action seeking a declaration that the statute violated the Home Rule Amendment of the Ohio Constitution because it was a general law that displaced municipal tow truck ordinances. The trial court granted summary judgment to the State, determining that the statute was a general law that does not violate the Constitution by infringing on the City’s home rule authority. The court of appeals reversed, concluding that the statute was not a general law and therefore unconstitutionally attempted to limit municipal home-rule authority. The Supreme Court affirmed in part and reversed in part, holding (1) the second sentence of the statute violates the Home Rule Amendment by prohibiting the “licensing, registering, or regulation” of entities that tow motor vehicles and so will be severed; but (2) the first sentence of the statute is a general law. View "Cleveland v. State" on Justia Law

A grand jury indicted Defendant for felonious assault and domestic violence. During a bench trial, the victim testified that Defendant was her boyfriend and had lived with her for about a year. The trial court found Defendant not guilty of felonious assault but guilty of attempted felonious assault and domestic violence. The court of appeals affirmed Defendant’s conviction for attempted felonious assault but reversed his conviction for domestic violence, ruling that the state must prove the victim and Defendant shared living expenses in order to convict Defendant of domestic violence. The Supreme Court reversed and reinstated the judgment of the trial court, holding that because the state proved that the victim was a family or household member, Defendant’s crime fell within the purview of the domestic violence statute. View "State v. McGlothan" on Justia Law

Appellant filed a motion for reclassification of his sex-offender status based on the Supreme Court’s decision in State v. Williams, which held that it was unconstitutional to apply sex-offender classifications under Ohio’s Adam Wash Act to defendants convicted prior to the effective date of that legislation. Appellant subsequently filed a petition for a writ of procedendo in the court of appeals to compel a ruling on his motion. The common pleas court subsequently issued a judgment granting Appellant’s motion and reclassifying Appellant’s sex-offender status. Thereafter, the court of appeals dismissed the petition for a writ of procedendo as moot. The Supreme Court affirmed because procedendo will not issue to compel the performance of a duty that has already been performed and because procedendo will not issue to address Appellant’s argument that the common pleas court judge failed to perform his duty. View "State ex rel. Clay v. Gee" on Justia Law

Defendant was charged with felony domestic violence, which contained an allegation that Defendant had been previously convicted of two offenses of domestic violence. After a jury trial, Defendant was convicted of domestic violence as charged. The appellate court reversed Defendant’s conviction, determining that the state failed to establish the necessary element of Defendant’s prior domestic violence convictions. The Supreme Court reversed the judgment of the appellate court and reinstated the judgment of the trial court, holding that because, during trial, the defense stipulated to the authenticity of Defendant’s two prior first degree misdemeanor domestic violence convictions, the state did properly prove the instant conviction. View "State v. Tate" on Justia Law

Appellant sustained a work-related injury and collected temporary total disability (TTD) compensation on her claim for certain injuries. Appellant later filed an application to add a psychological condition to her claim, at the same time requesting TTD compensation as a result of the condition. A hearing officer approved the additional condition but denied TTD compensation. Appellant subsequently filed another request for TTD compensation. A staff hearing officer awarded TTD compensation. The full Industrial Commission granted reconsideration and denied Appellant’s request for compensation, concluding that Appellant had voluntarily abandoned the entire workforce, and thus the claimed period of disability was not caused by the allowed conditions. Appellant filed a complaint seeking a writ of mandamus, which the court of appeals denied. The Supreme Court affirmed, holding that the Commission did not abuse its discretion in concluding that Appellant’s lack of earnings was not due to her psychological condition and that her failure to seek other employment was evidence she had voluntarily abandoned the workforce. View "State ex rel. Roxbury v. Indus. Comm'n" on Justia Law

Appellant pled guilty to several felonies. On March 11, 2002, the common pleas court entered a judgment entry of sentence. Eleven years later, Appellant filed a petition for writs of mandamus and prohibition, arguing that the March 11, 2002 judgment entry was defective because it did not indicate the manner of his conviction. On April 18, 2013, the trial court issued a nunc pro tunc judgment entry of sentence, this time indicating the manner of conviction. Appellant filed an amended petition, arguing that the nunc pro tunc entry did not cure the defective March 11, 2002 judgment entry. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant’s challenge to the validity of the March 11, 2002 judgment entry had no merit because the entry contained all four of the required elements under Ohio R. Crim. P. 32(C). View "State ex rel. Snead v. Ferenc" on Justia Law

On October 11, 2013, the Ohio Department of Medicaid (Department) submitted an application to the Ohio Controlling Board (Board) for an increase in its appropriation authority from the accounts holding federal Medicaid funds. The Board approved the Department's request on October 21, 2013, the effect of which was to provide medical services to Group VIII members under the Patient Protection and Affordable Care Act. The following day, Relators filed a request for writ of mandamus. Relators claimed that the Board violated Ohio Rev. Code 127.17, which provides that the Board shall take no action which does not carry out the legislative intent of the general assembly, by approving the Department's request for increased appropriation authority for the Hospital Care Assurance Match Fund. The Supreme Court denied the writ, concluding that Relators failed to establish a clear legal right to the requested relief and a clear legal duty on the part of the Board to undo the authorization of the expenditure of additional federal funds to provide medical insurance for Group VIII members. View "State ex rel. Cleveland Right to Life v. State of Ohio Controlling Bd." on Justia Law

Judge Tracie Hunter of the Hamilton County Court of Common Pleas presided over the twelve cases against six juvenile defendants underlying this appeal. Judge Hunter issued entries revoking the Cincinnati Enquirer's permission to broadcast, televise, photograph, or record courtroom proceedings. The appellate court granted the Enquirer an alternative writ of prohibition ordering Judge Hunter to stay the enforcement of the documents revoking the Enquirer's permission to broadcast, televise, photograph, or record the courtroom proceedings. Judge Hunter subsequently allowed the Enquirer's reporters into the courtroom but did so subject to certain express conditions, including the condition that the Enquirer not publish the juveniles' names. The Enquirer filed a motion for contempt, arguing that Judge Hunter violated the appellate court's order by making the Enquirer's access to the courtroom subject to conditions. The court of appeals granted the Enquirer's contempt motion. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion in granting the contempt motion for Judge Hunter's noncompliance with the appellate court's alternative writ. View "State ex rel. Cincinnati Enquirer v. Hunter" on Justia Law

Defendant was convicted of aggravated murder and sentenced to life imprisonment in 1990. The court of appeals affirmed. In 2009, Defendant argued that a final, appealable order never issued because the trial court failed to include the court's guilt-phase findings in the original judgment entry of sentence in violation of State v. Baker, which was decided in 2008. The trial court subsequently filed a new judgment entry and again sentenced Defendant to life imprisonment. The court of appeals reversed, concluding that Defendant's original sentence was not a final, appealable order and that the appellate court lacked jurisdiction to hear Defendant's original appeal. The Supreme Court vacated the judgment of the court of appeals and remanded for application of State v. Ketterer. On remand, the court of appeals reimposed its original reversal and remand. The Supreme Court reversed without reaching the proposition of law regarding Ketterer, holding (1) res judicata bars relitigation of matters that were raised or could have been raised on direct appeal when a final, appealable order was issued in accordance with the law at the time; and (2) because the sentencing entry issued in 1990 was a final, appealable order, the 2009 resentencing entry issued pursuant to Baker was a nullity. View "State v. Griffin" on Justia Law

The Power Siting Board issued a certificate to Black Fork Wind Energy, LLC to construct a proposed wind farm in Richland and Crawford counties. Appellants, who lived near or within the boundaries of the project area, appealed, arguing, among other things, that the Board violated their right to procedural due process by prohibiting Appellants from cross-examining Board staff members and by "prohibiting the presentation of evidence" at the evidentiary hearing on the application to site the project. The Supreme Court affirmed, holding that Appellants failed to sustain their burden of showing that the Board's order was unlawful or unreasonable. View "In re Application of Black Fork Wind Energy, LLC" on Justia Law