Justia Ohio Supreme Court Opinion Summaries

At issue was whether an exception in Ohio law providing that jail-time credit does not apply to the portion of a prison sentence that is imposed for a firearm specification, as applied in this case, violates equal-protection guarantees.Defendant was sentenced to an aggregate prison term that included two mandatory terms for firearm specifications. Before sentencing, Defendant filed a motion to credit the time that he had served in jail prior to sentencing toward the four years that he needed to serve for the firearm specifications. The trial court determined that the jail-time credit should be applied only to Defendant’s prison terms imposed for the underlying felonies. The court of appeals reversed, concluding that the failure to apply jail-time credit to Defendant’s firearm-specification terms would risk an equal protection violation should Defendant be granted judicial release. The Supreme Court revered, holding (1) the plain language of Ohio Rev. Code 2929.14(B)(1)(b) does not allow jail-time credit to be applied to mandatory firearm-specification sentences; and (2) there was no equal protection violation in this case. View "State v. Moore" on Justia Law

In this original action brought under Article II, Section 1g of the Ohio Constitution, the Supreme Court sustained the challenge brought by Relators regarding an initiative petition to place a proposed constitutional amendment on the November 6, 2018 ballot, concluding that Relators showed that Ohio law required invalidation of the petition.The proposed constitutional amendment at issue was called the “Kidney Dialysis Patient Protection Amendment.” Relators - the Kidney Dialysis Patient Protection Committee and its individual members and Secretary of State Jon Husted - argued in part that the petition must be invalidated because several circulation managers failed to comply with Ohio Rev. Code 3501.381(A). The Supreme Court invalidated the petition, holding that Relators demonstrated violations of section 3501.381(A) and that the constitutional challenges to that statute were without merit. View "Ohio Renal Ass’n v. Kidney Dialysis Patient Protection Amendment Committee" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant’s complaint for writs of prohibition and procedendo against Darke County Court of Common Pleas Judge Jonathan P. Hein, holding that Appellant was not entitled to either writ.In his complaint, Appellant asked for a writ of procedendo directing Judge Hein to vacate an order confirming the sale of property at a foreclosure sale. The court of appeals dismissed the procedendo claim as seeking the wrong form of relief. The Supreme Court affirmed, holding that procedendo was inappropriate because Appellant sought to undo a court order rather than to compel the judge to issue a ruling. As to the request for a writ of prohibition, the Supreme Court held that even if Appellant had sought to undo the confirmation order through a writ of prohibition, that request would be moot because the court of appeals had already vacated the confirmation order. Lastly, Appellant had an adequate remedy at law by way of appeal. View "State ex rel. Sponaugle v. Hein" on Justia Law

The Supreme Court answered a question certified to it by the United States Court of Appeals for the Sixth Circuit by holding that Ohio Rev. Code 1707.43, a provision of the Ohio Securities Act, does not impose joint and several liability on persons who aided in the purchase of illegal securities but did not participate or aid in the sale of the illegal securities.Plaintiffs filed a class action lawsuit in federal court seeking to hold Defendants, two trust companies, liable under the Ohio Securities Act, Ohio Rev. Code 1707.01 et seq., for their alleged roles in a Ponzi scheme. The district court granted Defendants’ motions to dismiss, holding that the trust companies’ mere involvement in the transactions at issue was insufficient to impose liability on them under the Act. The court of appeals then certified the above question to the Supreme Court. The Court answered that section 1707.43 does not impose joint and several liability on a person who, acting as the custodian of a self-directed individual retirement account (IRA), purchased, on behalf and at the direction of the owner of the self-directed IRA, illegal securities. View "Boyd v. Kingdom Trust Co." on Justia Law

The Supreme Court granted Cuyahoga County Prosecuting Attorney Michael C. O’Malley a writ of prohibition and ordered Cuyahoga County Common Pleas Court Judge Cassandra Collier-Williams to vacate her journal entry granting intervening-respondent Kelly Foust’s renewed motion for a capital resentencing hearing before a jury, holding that Judge Collier-Williams patently and unambiguously lacked jurisdiction to empanel a jury for a resentencing hearing in this capital-murder case when Foust validly waived a jury trial.Foust filed a renewed motion for a penalty phase hearing before a jury based on Hurst v. Florida, __ U.S. __ (2016), arguing that Hurst guaranteed a capital defendant an unequivocal right to a jury determination of every fact necessary to impose a death sentence and that he was entitled to withdraw his earlier jury waiver. The judge granted Foust’s renewed motion. The Supreme Court granted O’Malley a writ of prohibition, holding that O’Malley established that Judge Collier-Williams patently and unambiguously lacked jurisdiction to invalidate Foust’s previous jury waiver and empanel a jury for his resentencing hearing. View "State ex rel. O'Malley v. Collier-Williams" on Justia Law

In this expedited election case, the Supreme Court denied the writ of mandamus sought by Heaven Guest seeking to compel Ohio Secretary of State Jon Husted and the Columbiana County Board of Elections to place her name on the ballot on the November 6, 2018 ballot as an independent candidate for judge of the Columbiana County Court of Common Pleas, holding that Guest failed to show by clear an convincing evidence that Husted abused his discretion in finding that Guest remained “affiliated with the Democratic Party” and denying Guest’s nominating petition. Specifically, the Court held that Guest failed to show that Husted abused his discretion or disregarded the law when he rejected her petition. View "State ex rel. Guest v. Husted" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant’s petition for a writ of mandamus to compel the Ohio Parole Board to hold a parole hearing at which Appellant’s parole request would be given “meaningful consideration,” holding that Appellant did not demonstrate that the parole board failed to give his parole request meaningful consideration.On appeal, Appellant argued that the parole board did not give his parole request meaningful consideration as a result of materially false or misleading information in his parole record. The Supreme Court disagreed, holding that that Appellant failed to demonstrate that his parole record contained false or misleading information that might have adversely affected the board’s consideration of his parole request. View "State ex rel. Keith v. Department of Rehabilitation & Correction" on Justia Law

The Supreme Court held that Ohio Rev. Code 3314.08 authorizes the Ohio Department of Education (ODE) to base funding of an Internet-based community school - or e-school - on the duration of student participation.The Electronic Classroom of Tomorrow (ECOT), Ohio’s largest e-school, sought a permanent injunction and declaratory judgment seeking to bar ODE from requesting or considering data showing the duration of a student’s participation during its review of the e-school. The trial court denied ECOT’s claims, and the court of appeals affirmed. The Supreme Court affirmed, holding that section 3314.08 is unambiguous and does not bar the ODE from calculating funding based on a student’s participation. View "Electronic Classroom of Tomorrow v. Ohio Department of Education" on Justia Law

The Supreme Court affirmed the judgment of the Court of Appeals dismissing Appellant’s complaint for writs of mandamus and prohibition against Judge Patrick M. McGrath of the Court of Claims, holding the complaint was properly dismissed.Appellant, then an inmate, filed a negligence action against the Ohio Department of Rehabilitation and Correction. Judge McGrath dismissed the suit. The Court of Appeals reversed and remanded for further proceedings. While Appellant’s negligence action was pending on remand, Appellant filed his complaint for writs of prohibition and mandamus seeking an order prohibiting Judge McGrath from conducting proceedings on the defendant’s liability and requiring the judge to hold a damages-only hearing on Appellant’s negligence claim. The Court of Appeals dismissed the complaint. The Supreme Court affirmed, holding (1) the Court of Appeals correctly dismissed the complaint on the grounds that Appellant had misunderstood the Court of Appeals’ order to the Court of Claims, which held only that Appellant had met the liberal pleading standards required for complaints of negligence and not that Appellant had prevailed on the merits; and (2) nothing in the record suggested that Judge McGrath was refusing to comply with the Court of Appeals’ mandate, nor did the judge lack the authority to preside over a claim for relief in negligence. View "State ex rel. Evans v. McGrath" on Justia Law

The Supreme Court affirmed the decision of the Board of Tax Appeals (BTA) upholding a use-tax assessment on the purchases of natural gas by East Manufacturing Corporation (East) and not granting an exemption under Ohio Rev. Code 5739.011(B)(4), (B)(8), or (C)(5).East manufactures custom aluminum truck trailers. The tax commissioner issued a use-tax assessment for East’s natural gas purchases, exempting only the portion of natural gas used in painting operations. On appeal to the BTA, East argued that the natural gas used to heat the its buildings was exempt because maintaining the temperature at fifty degrees Fahrenheit or higher in the plant’s buildings was essential to its manufacturing process. The BTA affirmed the commissioner’s assessment on the portion of the natural gas that East used to heat its plant and denied East’s claim for exemption in its entirety. The Supreme Court affirmed, holding that the BTA correctly determined that East did not qualify for an exemption for total environmental regulation of a “special and limited area” of the facility, for items used in a manufacturing operation, or for gas used in a manufacturing operation. View "East Manufacturing Corp. v. Testa" on Justia Law