Justia Ohio Supreme Court Opinion Summaries

Property owners challenged the Lorain County auditor’s valuation of their single-family residence for tax year 2012, alleging that their 2011 purchase of the property was a recent arm’s-length sale that established a lower true value. The Lorain County Board of Revision (BOR) retained the auditor’s valuation, concluding that there was insufficient evidence to support the property owners’ complaint. The Board of Tax Appeals (BTA) reversed and valued the property according to the sale price, concluding that the transaction was recent, arm’s-length, and constituted the best indication of the property’s value. The Supreme Court reversed the decision of the BTA and reinstated the BOR’s valuation, holding that the BTA’s decision was unreasonable and unlawful because it mischaracterized and disregarded evidence showing that the sale was a forced sale. View "Utt v. Lorain County Board of Revision" on Justia Law

As part of an independent investigation into the murder conviction of Adam Saleh, Donald Caster, an Ohio attorney engaged by the Ohio Innocence Project, requested police records related to the arrest and investigation of Saleh. The Division of Police of the City of Columbus rejected the request, stating that no records could be produced until the “completion” of Saleh’s criminal case. By the time Caster made his request for public records, Saleh’s direct appeals had been exhausted for more than four years. Caster then filed this original action in mandamus. The Supreme Court granted the requested writ, holding that the specific-investigatory-work-product exception from required disclosure of public records set forth in Ohio Rev. Code 149.43(A)(2)(c) does not extend beyond the completion of the trial of the underlying criminal case at issue. View "State ex rel. Caster v. Columbus" on Justia Law

At issue in this real property valuation case was the proper valuation for tax year 2012 of an unused office warehouse property. The county auditor assigned a value of $1,388,700 to the property. The property owner (Appellant) sought a sale price valuation of $50,000 and an appraisal valuation of either $450,000 or $588,000. The board of revision (BOR) rejected the sale price on the grounds had not been consummated. The transfer allegedly occurred after the hearing held by the Board of Tax Appeals (BTA). The BTA rejected the sale price because the evidence of transfer was presented after the close of its hearing. The BTA then valued the property at $588,000. The Supreme Court vacated the BTA’s decision, holding that the BTA erred by (1) declining to consider Appellant’s post hearing evidence of the consummation of the sale for a price of $50,000; and (2) concluding that the BTA’s initial decision was based on a clerical error that could be corrected without weighing the conflicting evidence of the value of the property. Remanded for further proceedings. View "Emerson Network Power Energy Systems, North America, Inc. v. Lorain County Board of Revision" on Justia Law

At issue in this real property valuation case was the proper valuation for tax year 2009 of sixteen unsold units of a twenty-unit condominium development. The auditor assigned a value of $5,986,400 to the units. Before the Franklin County Board of Revision (BOR), the property owner presented an appraiser’s valuation of $2,900,000. The BOR adopted the appraisal valuation. The Board of Tax Appeals (BTA) reversed the decision of the BOR and reinstated the auditor’s valuation. The Supreme Court vacated the BTA’s decision, holding (1) the BTA reasonably rejected the appraiser’s opinion of value; but (2) the BTA should have performed an independent valuation of the property. Remanded with instructions that the BTA perform and independent valuation of the property. View "Columbus City Schools Board of Education v. Franklin County Board of Revision" on Justia Law

Appellant was indicted on eight counts of aggravated trafficking in drugs and one count of engaging in a pattern of corrupt activity. Appellant pleaded no contest to all nine counts. Appellant was sentenced to a separate term of imprisonment on each count, the longest being eleven years, with the terms to be served concurrently. At issue on appeal was whether controlled substance analogs were criminalized at the time Appellant allegedly committed the offense of aggravated trafficking of such substances. The court of appeals affirmed. The Supreme Court affirmed, holding that controlled substance analogs were criminalized at the time Appellant was arrested and indicted for selling them. View "State v. Shalash" on Justia Law

The Kenney Company, LLC, contested the auditor’s valuation of fourteen office condominium parcels for tax year 2009. The auditor valued the units at approximately $2,512,000. Before the Delaware County Board of Revision (BOR), The Kenney Company presented an appraisal that assigned an aggregate value of $1,430,000 to the unites. The BOR adopted the appraisal valuation. The Board of Tax Appeals (BTA) reversed the BOR’s decision and reinstated the auditor’s valuation. The Supreme Court affirmed, holding that the BTA acted reasonably by rejecting The Kenney Company’s appraisal and reinstating the auditor’s valuation. View "Olentangy Local Schools Board of Education v. Delaware County Board of Revision" on Justia Law

After a jury trial, Defendant was found guilty of possession of cocaine. The jury found that the amount of cocaine involved equaled or exceeded 100 grams. Defendant was sentenced to a mandatory term of eleven years pursuant to Ohio Rev. Code 2925.11(C)(4)(f) because the amount of cocaine was 100 grams or more. The appellate court reversed the judgment and vacated the mandatory prison sentence, holding (1) in prosecuting cocaine offenses under sections 2925.11(C)(4)(a) through (f), the state is required to prove that the weight of the actual cocaine possessed by the defendant met the statutory threshold; and (2) the state did not offer any evidence on whether the weight of the baggie’s contents in this case included ingredients other than cocaine, and therefore, the penalty enhancement under section 2925.11(C)(4)(f) must be vacated. The Supreme Court affirmed, holding that the state, in prosecuting cocaine offenses involving mixed substances under sections 2925.11(C)(4)[(b)] through (f), must prove that the weight of the cocaine meets the statutory threshold, excluding the weight of any filler materials used in the mixture. View "State v. Gonzales" on Justia Law

In 1988, Father was ordered to pay child support for his two children until the children were emancipated. In 2006, judgment entries were issued stating that the children were emancipated and ordering Father to pay arrearages owed. In 2009, an indictment was handed down containing nine counts related to Father’s failure to pay the ordered child support. The indictment was not served on Father until 2013. Father filed a motion to dismiss the indictment on due process and speedy trial grounds and because the six-year statute of limitations for felonies had run. The court dismissed all counts but two related to Father's failure to pay support from 2007 through 2009. Father then moved to dismiss those remaining counts, arguing that because his daughters were emancipated as of 2006, he had no duty to provide support to them after that date, and therefore, he was not obligated to pay support from 2007 through 2009. The trial court granted Father’s motion to dismiss. The Supreme Court affirmed, holding that Father was not subject to prosecution under section 2919.21(B) for his failure to make payments on the child-support arrearage established in the 2006 order when he had no current legal obligation to support his emancipated children. View "State v. Pittman" on Justia Law

During a bar fight, Defendant knowingly killed Antwon Shannon. After a jury trial, Defendant was convicted of aggravated murder and felony murder. Defendant appealed, arguing that his aggravated murder conviction was not supported by sufficient evidence of prior calculation and design. The court of appeals agreed and reversed the conviction for aggravated murder but upheld the felony murder conviction. The court then remanded the cause for resentencing. The Supreme Court affirmed, holding (1) the evidence did not show that the killing was done with prior calculation and design as required to sustain a conviction for aggravated murder; and (2) Defendant was properly convicted of felony murder. View "State v. Walker" on Justia Law

After a jury trial, Defendant was found guilty of three counts of aggravated robbery, three counts of rape, and other offenses. Defendant was fifteen years old at the time he committed the crimes. The trial court sentenced Defendant to the maximum prison term for each count. The sentence totaled 141 years in prison. At issue before the Supreme Court in this appeal was whether, pursuant to Graham v. Florida, a term-of-years prison sentence that exceeds a defendant’s life expectancy violates the Eighth Amendment’s prohibition against cruel and unusual punishments when it is imposed on a juvenile nonhomicide offender. The Supreme Court answered this question in the affirmative and remanded the cause to the trial court for resentencing, holding (1) Graham’s categorical prohibition of sentences of life imprisonment without the possibility of parole for juveniles who commit nonhomicide crimes applies to juvenile nonhomicide offenders who are sentenced to term-of-years sentences that exceed their life expectancies; and (2) therefore, Defendant’s 112-year sentence violates the Eighth Amendment. View "State v. Moore" on Justia Law