Justia Ohio Supreme Court Opinion Summaries

Vanessa Wells, a parent in the Lakota Local Schools district, filed a public records request seeking legal documentation related to the district's superintendent, Matt Miller, from the law firm of Elizabeth Tuck. Wells was concerned about allegations against Miller. The district's attorney, Brodi Conover, responded by providing a cease-and-desist letter but withheld other documents. Wells clarified her request to include all communications between Tuck and the school board regarding Miller from September 2022 to January 2023. Conover responded that certain communications were privileged and not subject to disclosure.Wells also requested all legal invoices from January 2022 to January 2023. Conover provided redacted invoices, omitting attorney names, hours, rates, and service descriptions, citing attorney-client privilege. In September 2023, after Wells filed a mandamus action, the district provided less-redacted invoices, retaining only the narrative descriptions and bank-account-related information.The Supreme Court of Ohio reviewed the case. It granted a writ of mandamus ordering the district to produce a demand letter from Tuck, rejecting the district's argument that it was protected under a federal settlement privilege. The court found that the district's reliance on Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc. was misplaced. The court awarded Wells $2,000 in statutory damages for the district's failure to timely produce the demand letter and the improperly redacted invoices. The court also awarded some attorney fees and court costs to Wells but denied additional attorney fees related to the invoices, finding no evidence of bad faith by the district. View "State ex rel. Wells v. Lakota Local Schools Board of Education" on Justia Law

Alphonso Mobley Jr. requested public records from the Hamilton County Prosecutor's Office, specifically certified statements created under former R.C. 309.16 for 2016 through 2020 and the office’s records-retention schedule. When Mobley did not receive a response, he filed a mandamus action to compel the production of these records and sought statutory damages under the Public Records Act, R.C. 149.43.The Supreme Court of Ohio previously issued a limited writ of mandamus, ordering the prosecutor to either provide the requested records or certify that they do not exist. The prosecutor complied by certifying that all responsive records in her possession were provided to Mobley on April 20, 2023. Additionally, the prosecutor obtained and provided records from the Hamilton County Board of County Commissioners that were not retained by her office. Mobley then filed a motion to proceed to judgment on the issue of statutory damages.The Supreme Court of Ohio determined that the prosecutor failed to comply with R.C. 149.43(B) by not responding to Mobley’s request within a reasonable period. The court noted that the request was narrow, involved few records, and did not require redactions. The prosecutor’s delay of almost three months was deemed unreasonable. Consequently, the court awarded Mobley $400 in statutory damages, calculated at $100 per business day for the four business days between the filing of the mandamus action and the prosecutor’s compliance. View "State ex rel. Mobley v. Powers" on Justia Law

In 1976, Prince Charles Cotten Sr. was convicted of aggravated murder and sentenced to death. The conviction included specifications for killing a police officer while attempting to escape apprehension. Following the United States Supreme Court's decision in Lockett v. Ohio, which declared Ohio's death-penalty statute unconstitutional, the Ohio Supreme Court commuted Cotten's sentence to life imprisonment.Cotten filed a complaint for a writ of habeas corpus in the Third District Court of Appeals in July 2023, arguing that his conviction and life sentence were invalid because they were based on an unconstitutional statute. The warden moved to dismiss the complaint, asserting that Cotten's life sentence had not expired and that the sentencing court had jurisdiction. The court of appeals granted the motion to dismiss, concluding that Cotten was imprisoned under a valid judgment from a court with proper jurisdiction and that his life sentence had not expired.The Supreme Court of Ohio reviewed the case and affirmed the court of appeals' dismissal. The court held that Cotten's life sentence was valid and that his arguments regarding the unconstitutionality of his original death sentence and the need for resentencing by a three-judge trial court were without merit. The court also denied Cotten's motion to strike documents attached to the warden's merit brief, which included a 2003 habeas corpus petition filed by Cotten that advanced similar arguments. The court concluded that Cotten's claims were not cognizable in habeas corpus and that the sentencing errors he alleged were not jurisdictional. View "Cotten v. Frederick" on Justia Law

Ronald Goldschmidt appealed the dismissal of his prohibition claim against Judge Alan Triggs and Magistrate Thomas Beridon of the Hamilton County Court of Common Pleas. Goldschmidt argued that Magistrate Beridon exceeded his authority by issuing a magistrate’s order instead of a magistrate’s decision regarding a charging order. This charging order was related to a civil action where Goldschmidt was found liable for over $1.5 million, and Elm Investment sought to collect on this judgment through Goldschmidt’s membership interests in several limited-liability companies.The First District Court of Appeals dismissed Goldschmidt’s claim, holding that the trial court had jurisdiction to issue the charging order and that any error in how it was issued was a matter of the exercise of jurisdiction, not a lack of it. The court also found that Goldschmidt had an adequate remedy in the ordinary course of law by filing a motion to set aside the magistrate’s order.The Supreme Court of Ohio reviewed the case de novo and affirmed the First District’s judgment. The court held that the issuance of the charging order as a magistrate’s order did not exceed the trial court’s subject-matter jurisdiction. It noted that procedural errors by a magistrate do not affect the trial court’s jurisdiction and render decisions voidable, not void. The court concluded that Goldschmidt had an adequate remedy in the ordinary course of law through a motion to set aside the magistrate’s order and an appeal from any subsequent ruling on such a motion. Therefore, the court affirmed the dismissal of Goldschmidt’s complaint for a writ of prohibition. View "State ex rel. Goldschmidt v. Triggs" on Justia Law

Moraine Wind, L.L.C. and other out-of-state wind farms applied to the Public Utilities Commission of Ohio (PUCO) for certification as eligible Ohio renewable-energy-resource-generating facilities. Carbon Solutions Group, L.L.C. (CSG), whose clients include Ohio-based renewable-energy suppliers, opposed the applications. PUCO approved the applications in September 2023. CSG filed an application for rehearing, which PUCO purported to grant for the limited purpose of further consideration, effectively extending the statutory deadline for a decision.CSG appealed PUCO's decision to the Supreme Court of Ohio, arguing that PUCO's failure to grant or deny the rehearing application within 30 days resulted in a denial by operation of law, as per R.C. 4903.10. PUCO moved to dismiss the appeal, claiming the court lacked jurisdiction because the rehearing application was still pending.The Supreme Court of Ohio held that PUCO's order granting rehearing for further consideration did not constitute a substantive grant of rehearing. The court emphasized that R.C. 4903.10 requires PUCO to grant or deny an application for rehearing within 30 days, and failure to do so results in a denial by operation of law. The court found that PUCO's practice of extending the deadline was not supported by statute and undermined the legislative intent for timely judicial review. Consequently, the court denied PUCO's motion to dismiss, affirming that CSG's application for rehearing was denied by operation of law, and the appeal was timely filed. View "In re Application of Moraine Wind, L.L.C." on Justia Law

The administrator of a deceased woman’s estate filed a complaint alleging medical malpractice and wrongful death against a doctor, the doctor’s employer, a hospital, and Medicare. The doctor and his employer included the affirmative defenses of insufficiency of process and insufficiency of service of process in their answer. Over two years later, they moved for summary judgment, arguing that the case had not commenced timely because the doctor had not been served with the complaint. The administrator opposed, claiming the doctor waived his defense by participating in the litigation. The trial court granted summary judgment, and the First District Court of Appeals affirmed.The administrator appealed to the Supreme Court of Ohio, urging it to overrule its decision in Gliozzo v. Univ. Urologists of Cleveland, Inc., which held that active participation in litigation does not waive the defense of insufficiency of service of process if properly raised and preserved. The Supreme Court of Ohio declined to overrule Gliozzo, reaffirming that the defense is not waived by participation in litigation if it is properly raised and preserved. The court emphasized that the burden of perfecting service lies with the plaintiff and that the rules of civil procedure govern the conduct of all parties equally.The Supreme Court of Ohio held that Dr. Ahmad properly preserved his insufficiency-of-service-of-process defense and that the administrator never perfected service of the complaint on him. Consequently, the trial court correctly dismissed the claims against Dr. Ahmad and his employer. The judgment of the First District Court of Appeals was affirmed. View "Ackman v. Mercy Health W. Hosp., Inc." on Justia Law

A pipeline running through 13 Ohio counties was valued by the Ohio Tax Commissioner at $1,620,358,699 for tax year 2019. The pipeline's owner, Nexus Gas Transmission, L.L.C., appealed this valuation to the Board of Tax Appeals (BTA), arguing for a lower value of $615,695,340. The dispute was settled through an agreement between Nexus and the Tax Commissioner, setting the pipeline's value at $950,000,000 for 2019 and resolving valuation issues for 2020 and 2021. The Tax Commissioner issued a final determination reflecting these agreed values.The Lorain County Auditor, dissatisfied with the settlement, appealed the Tax Commissioner’s final determination to the BTA, arguing that the Commissioner had not followed statutory criteria in valuing the property. The BTA dismissed the appeal, stating that the valuation dispute had been resolved through the settlement agreement and that the auditor had not participated in the initial appeal process.The Supreme Court of Ohio reviewed the case, focusing on reconciling the Tax Commissioner’s authority to settle tax disputes under R.C. 5703.05(C) with the county auditor’s right to appeal under R.C. 5717.02(A). The court held that while a county auditor can appeal a final determination, this right does not extend to challenging the substance of a settlement agreement reached by the Tax Commissioner. The court emphasized that allowing such appeals would undermine the Commissioner’s statutory authority to settle disputes. The court affirmed the BTA’s decision, concluding that the county auditor’s appeal, which contested the valuation methodology rather than the validity of the settlement itself, could not proceed. View "Snodgrass v. Harris" on Justia Law

Christopher Hildebrant, a real-estate developer, facilitated a property sale in 2011 and expected consulting fees from both the seller and the buyer. During the transaction, Hildebrant alleged that Thomas Weidman, a trustee on the Sycamore Township Board, demanded a kickback. To avoid paying, Hildebrant created a fictitious email account and sent himself an email portraying Weidman as demanding payments. This email was forwarded to another party but remained private until 2020, when Hildebrant showed it to other township officials during a separate transaction. Weidman learned of the email in November 2020 during an investigation and received a copy in January 2021.The Warren County Court of Common Pleas granted Hildebrant’s motion for summary judgment, ruling that Weidman’s defamation claim was time-barred by the statute of limitations, which began when the email was first sent in 2011. The court also ruled that Weidman’s claims for intentional infliction of emotional distress (IIED) and false-light invasion of privacy were similarly time-barred as they were derivative of the defamation claim.The Twelfth District Court of Appeals reversed, holding that the discovery rule applied to defamation claims when the publication was secretive or inherently unknowable. The court ruled that Weidman’s claims were not time-barred because he could not have known about the defamatory email until it was disclosed to him in 2020.The Supreme Court of Ohio affirmed the appellate court’s decision, holding that the discovery rule applies to libel claims when the publication is secretive or inherently unknowable. The court also held that the discovery rule applies to derivative claims like IIED and false-light invasion of privacy when they are based on the same allegations as the libel claim. The case was remanded to the Warren County Court of Common Pleas for further proceedings. View "Weidman v. Hildebrandt" on Justia Law

A public children-services agency determined that an allegation of child abuse against Kelly D. Kyser was substantiated. Kyser challenged this finding through the agency’s administrative-review process, but her appeal was unsuccessful. She then appealed the agency’s decision to the Summit County Court of Common Pleas. The court dismissed her appeal as untimely, and the Ninth District Court of Appeals affirmed this decision.The Supreme Court of Ohio reviewed the case. The court noted that under R.C. 2506.01, a person may appeal a final order or decision of an agency that determines their rights, duties, privileges, benefits, or legal relationships. However, the court found that an agency’s disposition finding that an allegation of child abuse is substantiated does not determine any of these things. The court explained that while certain consequences may result from such a finding, the agency’s disposition itself does not determine those consequences.The Supreme Court of Ohio concluded that the common pleas court did not have jurisdiction to hear Kyser’s appeal because the agency’s disposition was not a final order under R.C. 2506.01. As a result, the Supreme Court vacated the Ninth District Court of Appeals’ judgment and dismissed the appeal. View "Kyser v. Summit Cty. Children Servs." on Justia Law

Jeffrey Harmon and David Beasley, longtime employees of the City of Cincinnati and members of a city-employees union, were placed on leave under a Temporary Emergency Leave (TEL) program implemented in April 2020 in response to the COVID-19 pandemic. They used accrued paid leave during this period and appealed the city's decision to the Cincinnati Civil Service Commission, arguing that the city had not followed proper layoff procedures. The commission determined that the TEL program was not a layoff and denied their request for a hearing, instead holding an "appearance."Harmon and Beasley appealed the commission's decision to the Hamilton County Court of Common Pleas, which reversed the commission's determination and remanded the matter for a hearing. The city appealed to the First District Court of Appeals, arguing that the common pleas court lacked jurisdiction because the matter was governed by the collective-bargaining agreement (CBA) and the commission's decision was not the result of a quasi-judicial proceeding. The First District held that the common pleas court had jurisdiction under the CBA and R.C. 2506.01, as the commission's decision was an adjudication from a quasi-judicial proceeding.The Supreme Court of Ohio reviewed the case and affirmed the First District's judgment. The court held that Harmon and Beasley had a right to appeal the commission’s decision under R.C. 2506.01 and were not precluded by R.C. 4117.10. The court determined that the commission was required to hold a hearing under the Cincinnati Civil Service Rules, and its failure to do so did not divest the common pleas court of jurisdiction. The court concluded that the commission's decision was the result of a quasi-judicial proceeding, thus allowing the appeal to the common pleas court. View "Harmon v. Cincinnati" on Justia Law