Justia Ohio Supreme Court Opinion Summaries

At issue was whether the trial court had authority to enjoin the state from enforcing new statutes as punishment for contempt of court.The court of common pleas found the state to be in contempt of a court order that permanently enjoined the state from enforcing several statutes that the court had declared unconstitutional. The contempt finding was based on the General Assembly’s enactment of new statutes that reduced funding to cities that were not acting in compliance with the statutes that were previously declared unconstitutional. As punishment for the contempt, the state was enjoined from enforcing the new laws. The court of appeals affirmed. The Supreme Court reversed the judgment of the court of appeals, vacated the order of contempt, and dissolved the injunction against enforcing the spending provisions enacted by 2015 Am.Sub.H.B. No. 64 (H.B. 64), holding that the trial court lacked authority to enjoin enforcement of the spending provisions enacted in H.B. 64 because the statutes had not been declared unconstitutional. View "Toledo v. State" on Justia Law

A social worker’s statutory duty to cooperate and share information with law enforcement regarding a child abuse investigation does not render the social worker an agent of law enforcement for purposes of the Fifth and Sixth Amendments to the United States Constitution if the social worker interviews an alleged perpetrator unless the evidence demonstrates that the social worker acted at the direction or under the control of law enforcement.Defendant was convicted of kidnapping, gross sexual imposition, and two counts of rape. Social worker and child advocate Holly Mack interviewed Defendant after he was arrested. During trial, defense counsel objected to Mack’s testimony about the statements Jackson had made to her because she questioned him “as an agent of the State and law enforcement” and failed to notify Defendant of his Miranda rights. The trial court allowed Mack to testify. The appellate court reversed the convictions, holding that Mack acted as an agent of law enforcement when she interrogated Defendant. The Supreme Court reversed, holding that no evidence indicated that Mack acted at the direction or under the control of law enforcement when she interviewed Jackson. View "State v. Jackson" on Justia Law

The Supreme Court granted a writ to Relator, who filed a complaint for a writ of mandamus to compel the common pleas court to enforce its 2013 order sealing the record in a criminal case against Relator and to rule on his 2017 motion to reseal the record.Relator alleged that after the records at issue were sealed the court of appeals made his appellate records public again. Relator then filed an emergency motion for an order resealing his records. When no action was taken to enforce the order to seal or ruling on the motion to reseal Relator filed his complaint for a writ of mandamus. The common pleas court filed a motion to dismiss the complaint. The Supreme Court denied the motion to dismiss, sue sponte converted Relator’s complaint to a request for a writ of procedendo, granted a writ ordering the common pleas court to rule on Relator’s motion to reseal, and granted Relator’s motion to seal the pleadings filed in this original action. View "State ex rel. Doe v. Gallia County Court of Common Pleas" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting a writ of mandamus ordering the Industrial Commission to vacate its order allocating the cost of a permanent-total-disability award between two different employers and issue an amended order.Appellee filed an application for permanent-total-disability compensation based on three workers’ compensation claims for work-related injuries she received while working for two different employers. A staff hearing officer granted the application. Appellant, one of Appellee’s employers, filed this mandamus action challenging the Commission’s allocation of the cost of the award among the three claims. The court of appeals ordered the Commission to vacate the portion of the hearing officer’s order allocating the cost of the award. The Supreme Court affirmed, holding that the Commission abused its discretion by failing to explain the basis for the specific allocations of the award among the three claims. View "State ex rel. Penske Truck Leasing Co. v. Industrial Commission" on Justia Law

The Supreme Court reversed the judgment of the court of appeals granting a writ of mandamus that ordered the administrator of the Bureau of Workers’ Compensation (Bureau) to vacate the order of the administrator’s designee finding that Daily Services LLC was the successor to I-Force, LLC and was responsible for I-Force’s rights and obligations, holding that Daily Services failed to demonstrate that it was entitled to relief in mandamus.After Daily Services received from the Bureau an invoice for more than $3.48 million for I-Force’s unpaid premiums, it filed a protest. An adjudicating committee determined that Daily Services was the successor to I-Force under former Ohio Adm.Code 4123-17-02(C)(1). The administrator’s designee upheld the decision. The court of appeals, however, concluded that Daily Services did not “wholly succeed” the business operations of I-Force. The Supreme Court reversed, holding (1) the Bureau did not abuse its discretion when it determined that Daily Services wholly succeeded the business operations of I-Force even if it did not assume every customer, employee, or lease held by I-Force; and (2) the Bureau’s statutory obligation to safeguard the Workers’ Compensation Fund authorizes it to find that an employer is a “successor in interest” when that employer attempts to evade workers’ compensation liabilities. View "State ex rel. Daily Services, LLC v. Morrison" on Justia Law

The Supreme Court reversed the judgment of the court of appeals granting a motion to dismiss Appellant’s complaint for a writ of mandamus challenging the Industrial Commission’s determination that it had continuing jurisdiction to reconsider a previous order denying a claim for death benefits because of a clear mistake of fact regarding how the decedent worker died, holding that the complaint did state a claim for relief.Appellant’s complaint for a writ of mandamus alleged that the Commission abused its discretion in determining that the staff hearing officer had based the disallowance of the claim for death benefits on a clear mistake of fact. Because this question involved whether there was a factual mistake sufficient to invoke the continuing-jurisdiction provisions of Ohio Rev. Code 4123.52, the question was a proper subject matter for an action seeking a writ of mandamus. Therefore, the court of appeals erred in dismissing the action on the basis that the Commission’s decision to exercise its continuing jurisdiction was appealable to the court of common pleas. View "State ex rel. Belle Tire Distributors, Inc. v. Industrial Commission of Ohio" on Justia Law

The Supreme Court reversed the judgment of the court of appeals granting a motion to dismiss Appellant’s complaint for a writ of mandamus challenging the Industrial Commission’s determination that it had continuing jurisdiction to reconsider a previous order denying a claim for death benefits because of a clear mistake of fact regarding how the decedent worker died, holding that the complaint did state a claim for relief.Appellant’s complaint for a writ of mandamus alleged that the Commission abused its discretion in determining that the staff hearing officer had based the disallowance of the claim for death benefits on a clear mistake of fact. Because this question involved whether there was a factual mistake sufficient to invoke the continuing-jurisdiction provisions of Ohio Rev. Code 4123.52, the question was a proper subject matter for an action seeking a writ of mandamus. Therefore, the court of appeals erred in dismissing the action on the basis that the Commission’s decision to exercise its continuing jurisdiction was appealable to the court of common pleas. View "State ex rel. Belle Tire Distributors, Inc. v. Industrial Commission of Ohio" on Justia Law

The unambiguous language of Ohio Rev. Code 2744.02(B)(3), which provides that a political subdivision may be held liable for the negligent failure to keep public roads in repair and the negligent failure to remove obstructions from them, required that the City of Campbell be granted judgment as a matter of law in this personal injury action seeking recovery based on the City’s alleged failure to remove foliage that was growing thirty-four feet in front of a stop sign.The trial court denied the City’s motion for summary judgment. The appellate court affirmed, concluding that there were genuine issues of material fact regarding whether section 2744.02(B)(3) applied as an exception to the City’s immunity from suit. The Supreme Court reversed, holding that because the stop sign at issue was in repair and not obstructed, this matter must be remanded to the trial court to dismiss Plaintiff’s claims against the City. View "Pelletier v. City of Campbell" on Justia Law

The Supreme Court affirmed the judgments of the two courts of appeals dismissing Appellant’s petition for a writ of habeas corpus and Appellant’s petition for writs of prohibition and mandamus.Appellant was convicted in two separate common pleas cases, one involving the murder and robbery of Christine Kozak (the Kozak case) and the other case involving the robberies of David Sotka and the Lawson Milk Company (the Sotka case). In both of his petitions, Appellant challenged the jurisdiction of the general division of the common pleas court in both the Kozak case and the Sotka case. Both petitions alleged that there was an allegedly defective transfer from the juvenile division. The Supreme Court held (1) the court of appeals correctly dismissed Appellant’s habeas petition for failure to state a claim cognizable in habeas corpus; and (2) Appellant had an adequate remedy by way of appeal to challenge the validity of the bindover, and therefore, Appellant’s request for writs of prohibition and mandamus were properly dismissed. View "Johnson v. Sloan" on Justia Law

The Supreme Court granted the writ of habeas corpus sought by Tyrone Oliver and commanded Oliver’s immediate release from incarceration.In 1993, Oliver was sentenced to an indeterminate prison sentence of eight to twenty-five years for involuntary manslaughter. The Bureau of Sentence Computation calculated his maximum-sentence release date as January 9, 2018. Oliver received parole release in July 2003. In February 2005 he pleaded guilty to a domestic violence charge and received a two year sentence. On January 26, 2018, Oliver filed this petition for writ of habeas corpus, arguing that he was entitled to immediate release. The Supreme Court agreed, holding that Oliver’s 2005 sentence for domestic violence was to be served concurrently with, not consecutively to, his 1993 sentence for involuntary manslaughter, and therefore, Oliver had served his maximum sentence and was entitled to immediate release. View "State ex rel. Oliver v. Turner" on Justia Law