Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the court of appeals’ dismissal of Appellant’s petition for a writ of habeas corpus because his claims were not cognizable in habeas corpus.Appellant pleaded guilty to three counts of rape. The common pleas court sentenced Appellant to nine years’ imprisonment for each count and ordered two of the three sentences to run consecutively. Appellant filed a petition for a writ of habeas corpus arguing that the trial court failed to make the requisite findings under Ohio Rev. Code 2929.14(C)(4) before imposing consecutive sentences. The court of appeals dismissed the petition. The Supreme Court affirmed the dismissal of the petition because Appellant’s claims were not cognizable in habeas corpus. View "State ex rel. Quillen v. Wainwright" on Justia Law

The Supreme Court reversed the decision of the Board of Tax Appeals (BTA) vacating the decision of the Franklin County Board of Revision (BOR), which partially reduced the value of certain property for tax year 2012. The BOR partially reduced the value of the property based on a sheriff’s-sale appraisal. The BTA concluded that this evidence was unreliable and that the record contained no other evidence from which a value could be determined. The BTA vacated the BOR’s decision and remanded the case to the BOR with directions to determine a value based on competent and probative evidence. The Supreme Court reinstated the county auditor’s original valuation, holding that that BTA erred in remanding the case to the BOR. View "South-Western City Schools Board of Education v. Franklin County Board of Revision" on Justia Law

The Board of Tax Appeals (BTA) erred in adopting the Franklin County Board of Revision’s (BOR) determination of value of Appellee’s property for tax year 2011.For tax year 2011, the Franklin County auditor valued the property at issue at $328,700. Appellee filed a complaint against the valuation, seeking a reduction to $165,000. The BOR reduced the value to $272,000. The BTA adopted the BOR’s valuation. The Supreme Court reversed, holding (1) the BTA erred in its application of the rule set forth in Bedford Board of Education v. Cuyahoga County Board of Revision, 875 N.E.2d 913 (Ohio 2007); and (2) the county auditor’s valuation should be reinstated, rather than the case remanded to the BTA for an independent determination of value. View "South-Western City Schools Board of Education v. Franklin County Board of Revision" on Justia Law

At issue was whether the trial court erred in imposing a sentence, which included both a prison term and community control sanctions at the same time, where the community control sanctions continued after the completion of the prison sentence, which included additional confinement in a community-based-correctional-facility (CBCF).Defendant was sentenced to a prison term for sexual-battery and to community-control supervision for domestic violence. The community-control sentence included several conditions, including the condition that, upon his release from prison for the sexual battery count, Defendant must transfer to a CBCF. The court of appeals vacated the sentence on the domestic-violence count, concluding that the sentence was a split sentence not permitted by statute. The Supreme Court reversed the judgment of the court of appeals and reinstated the sentence imposed on the domestic-violence count except for the condition requiring Defendant’s placement in a CBCF upon his release from prison, which the Court vacated, holding (1) the trial court’s imposition of a CBCF term as a community-control sanction, to be served consecutively to a prison term imposed on a separate offense, was improper; but (2) the property remedy is to vacate only the improperly imposed residential sanction and leave the remaining conditions of the community-control sentence intact. View "State v. Paige" on Justia Law

At issue was whether the trial court erred in imposing a sentence, which included both a prison term and community control sanctions at the same time, where the community control sanctions continued after the completion of the prison sentence, which included additional confinement in a community-based-correctional-facility (CBCF).Defendant was sentenced to a prison term for sexual-battery and to community-control supervision for domestic violence. The community-control sentence included several conditions, including the condition that, upon his release from prison for the sexual battery count, Defendant must transfer to a CBCF. The court of appeals vacated the sentence on the domestic-violence count, concluding that the sentence was a split sentence not permitted by statute. The Supreme Court reversed the judgment of the court of appeals and reinstated the sentence imposed on the domestic-violence count except for the condition requiring Defendant’s placement in a CBCF upon his release from prison, which the Court vacated, holding (1) the trial court’s imposition of a CBCF term as a community-control sanction, to be served consecutively to a prison term imposed on a separate offense, was improper; but (2) the property remedy is to vacate only the improperly imposed residential sanction and leave the remaining conditions of the community-control sentence intact. View "State v. Paige" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court related to Appellant’s second application for postconviction DNA testing under Ohio Rev. Code 2953.71 through 2953.81, holding that Appellant may appeal the trial court’s determination of what constitutes “the results” of the DNA testing.Appellant, who was sentenced to death for first degree murder, sought postconviction DNA testing. The trial court ordered the Ohio Bureau of Criminal Investigation (BCI) to collect DNA evidence from a cigarette butt and, later, to determine the quantity and quality of biological material on ring boxes and shell casings. On appeal, Appellant argued that the State was required to provide him with all documentation relating to the DNA testing of the cigarette butt and that his objection relating to the BCI’s selection as the testing authority and to its preliminary determination as to the scientific suitability for DNA testing of the shell casings and ring boxes should have been upheld. The Supreme Court held that Appellant was entitled to relief on his claim that the trial court failed to provide him with “the results of the testing” as required under section 2953.81(C) and dismissed Appellant’s remaining propositions of law. View "State v. Noling" on Justia Law

The Supreme Court affirmed Defendant’s convictions for three counts of aggravated murder and one count of attempted murder. The court affirmed the trial court’s imposition of three sentences of death but vacated Defendant’s sentence for his noncapital convictions, holding that the sentencing hearing and entry in this case were insufficient to satisfy State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) and that a nun pro tunc entry did not suffice to cure the error. The Supreme Court remanded the cause to the trial court for the limited purpose of conducting a new sentencing hearing consistent with this decision. View "State v. Beasley" on Justia Law

Here, the Supreme Court withdrew its prior opinion affirming the judgment of the court of appeals, which referred this case to a magistrate, who then purported to dismiss the petition sua sponte. Upon further consideration, the Supreme Court concluded that it lacked jurisdiction to hear and decide this case, which Appellant filed in the court of appeals seeking a writ of mandamus against the Ohio Adult Parole Authority. Under Ohio R. Civ. P. 53, a magistrate’s decision, standing alone, is not a final, appealable order, and because the court of appeals did not adopt the magistrate’s decision, Appellant never received a final, appealable order. View "State ex rel. Robinson v. Adult Parole Authority" on Justia Law

The Supreme Court reversed the decision of the court of appeals granting a writ of habeas corpus to Appellee and ordering his immediate discharge from the Ross Correctional Institution. In his petition, Appellee, who was seventeen years old at the time of the offense for which he was convicted, argued that the general division of the common pleas court lacked jurisdiction to try him as an adult because the juvenile court had failed to meet the requirements of Ohio Rev. Code 2152.12(G) before transferring his case. Specifically, Appellee argued that the failure to notify his legal custodian, his grandmother, of the transfer hearing was a violation of the statute, and therefore, the common pleas court lacked jurisdiction over the matter. The court of appeals agreed. The Supreme Court reversed, holding that the juvenile court satisfied the statutory requirements by serving notice on Appellee’s biological mother. View "Turner v. Hooks" on Justia Law

The Supreme Court reversed the decision of the Board of Tax Appeals (BTA) concluding that Taxpayer’s challenge to the taxable value assigned to its property for tax year 2012 was barred because taxpayer waited too long to notify the Board of Revision (BOR) that it wished to pursue a continuing complaint for tax year 2012. Taxpayer did not file a new complaint for the 2012 tax year but, rather, relied upon the continuing-complaint jurisdiction provided for in Ohio Rev. Code 5715.19(D). The Supreme Court held that the time limitation imposed by the BTA was contrary to the plain language of Ohio Rev. Code 5715.19(D) and that, under the statute, the BOR had continuing-complaint jurisdiction to consider Taxpayer’s request for tax year 2012. View "MDM Holdings, Inc. v. Cuyahoga County Board of Revision" on Justia Law