Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the Board of Tax Appeals (BTA), which adopted $8,492,910 as the property value for a thirty-seven-acre parcel of real property for tax years 2011 through 2013. The BTA based its decision on the purchase price that Buckeye Terminals, LLC, the landowner, reported on a June 2011 conveyance fee statement. On appeal, Buckeye Terminals argued that the reported price did not accurately reflect the true value of the real property. The Supreme Court held that the BTA’s decision to retain the Board of Revision’s valuation for tax years 2011 through 2013, based solely on the June 2011 conveyance fee statement rather than an independent determination of the value of the property, was unreasonable and unlawful. View "Buckeye Terminals, LLC v. Franklin County Board of Revision" on Justia Law

In this original action, Relator requested a writ of prohibition to void the court of appeals’ judgment in the State’s appeal of a judgment granting Relator postconviction relief, to void the common pleas judge’s subsequent orders on remand, and to preclude the court of appeals from ruling on Relator’s direct appeal of the judge’s denial of his motion for a new trial. Upon the State’s appeal, the court of appeals reversed the court of common pleas’ determination that Relator, who was convicted of murdering his former wife, was actually innocent of the aggravated murder and grant of postconviction relief under Ohio Rev. Code 2953.21. On remand, a new common pleas judge reinstated Relator’s aggravated murder conviction and sentence. The Supreme Court denied the writ of prohibition, holding (1) Ohio Rev. Code 2945.67(A) and 2953.23(B) unambiguously allow the State an absolute right to appeal a judgment granting postconviction relief; and (2) therefore, Respondents’ exercise of jurisdiction following the trial court’s judgment was not unauthorized by law. View "State ex rel. Prade v. Ninth District Court of Appeals" on Justia Law

The Supreme Court affirmed the decision of the Board of Tax Appeals (BTA) that adopted an allocated portion of a bulk-sale price as the property value for tax year 2011 for two parcels of property along the Ohio River. The owner of the property appealed, arguing that the BTA erred in not reducing the sale price by an amount that was contractually allocated to goodwill. The Supreme Court disagreed, holding (1) the landowner’s burden was to show a proper sale-price allocation; (2) the BTA reasonably applied the evidentiary standard; (3) the BTA reasonably rejected the landowner’s appraisal; and (4) the landowner failed to state a constitutional claim. View "Cincinnati School District Board of Education v. Hamilton County Board of Revision" on Justia Law

The Supreme Court denied Relators’ petition seeking a writ of mandamus compelling the Lorain County Board of Election to certify an initiative petition for the November ballot. The petition sought to repeal a county permissive sales tax. The Lorain County Board of Elections voted not to place the petition on the general election ballot on the grounds that Ohio Rev. Code 5739.022 does not permit an initiative petition to repeal a county permissive tax that was not passed or enacted as an emergency measure. The Supreme Court agreed, holding that section 5739.022(A) did not provide Relators the clear legal right to have the petition placed on the November ballot. View "State ex rel. Repeal Lorain County Permissive Sales Tax Committee v. Lorain County Board of Elections" on Justia Law

The Supreme Court affirmed the decision of the Board of Tax Appeals (BTA) that valued the land underlying the North Bank Condominiums in Franklin County for tax year 2013. The BTA adopted the value found in an appraisal report submitted by the Columbus City Schools Board of Education (BOE). The unit owners appealed, arguing that the BTA should have adopted the land value in their appraisal report rather than the higher value in the BOE’s appraisal report. The Supreme Court affirmed, holding that the BTA did not abuse its discretion in finding the BOE’s appraisal to be more probative and in thus adopting the land value found in the BOE’s appraisal. View "NWD 300 Spring, LLC v. Franklin County Board of Revision" on Justia Law

The Supreme Court reversed the decision of the Board of Tax Appeals (BTA) that increased the tax value of property owned by State Farm Mutual Automobile Insurance Company. On appeal, State Farm challenged the BTA’s reliance on a November 2013 sale price in ordering an increase from the $14,000,000 value adopted by the BTA for tax year 2011 to $25,092,330 for tax year 2012. The Supreme Court reversed, holding that the 2013 sale price was not indicative of value because it was not at arm’s length for purposes of determining property value. The court then ordered that the Board of Revision’s value of $14,000,000 be reinstated for tax year 2012. View "Columbus City Schools Board of Education v. Franklin County Board of Revision" on Justia Law

An employer does not face liability for the violation of a specific safety requirement (VSSR) when it lacked knowledge of a specific danger requiring a safety device.Employee suffered a head injury while working for Employer. The Industrial Commission awarded workers’ compensation benefits and granted an additional award to Employee based upon its finding that Employer had violated a specific safety requirement in failing to provide Employee with protective headgear. Employer filed a mandamus action in the court of appeals challenging the additional award. The court of appeals denied the writ, concluding that Employer had waived a central issue in its mandamus action by not raising it during proceedings before the Commission. The Supreme Court reversed and ordered a limited writ of mandamus ordering the Commission to determine whether Employer knew or should have known about the latent defect at the time that Employee was injured, holding (1) waiver did not apply in this case because the central issue raised in Employer’s mandamus action was not raised by the parties below; and (2) if Employer lacked the requisite knowledge of a design defect at the time of the injury, it cannot have violated a specific safety requirement. View "State ex rel. Camaco, LLC v. Albu" on Justia Law

The Supreme Court issued a writ of mandamus ordering the Industrial Commission to vacate its award to Employee of permanent-partial-disability compensation under Ohio Rev. Code 4123.57(A) and to issue an order denying the award, holding that, pursuant to State ex rel. Ohio Presbyterian Retirement Services, Inc. v. Industrial Commission (“Ohio Presbyterian I”), 79 N.E.3d 522 (Ohio 2016), when an injured employee is receiving permanent-total-disability compensation pursuant to Ohio Rev. Code 4123.58, the Commission is without statutory authority to grant in the same claim permanent-partial-disability compensation under section 4123.57(A). Employee in this case moved the court to reconsider its holding in Ohio Presbyterian I. The Supreme Court granted the motion, reopened the case for further consideration, and concluded that its holding in Ohio Presbyterian I was not made in error. Because the Commission granted Employee permanent-total-disability compensation and then permanent-partial-disability compensation in the same claim, the Supreme Court issued a writ of mandamus ordering the Commission to vacate its award of permanent-partial-disability compensation to Employee under section 4123.57(A) and to issue an order denying the award. View "State ex rel. Ohio Presbyterian Retirement Servs., Inc. v. Industrial Commission" on Justia Law

The Supreme Court affirmed the orders issued by the Public Utilities Commission of Ohio (PUCO) finding that the presence of stray gas near Appellants’ properties created a verifiable safety hazard that justified Columbia Gas of Ohio, Inc.’s discontinuing gas service to the homes. Specifically, the court held (1) Appellants’ argument that PUCO misinterpreted Ohio Rev. Code 4905.20 and 4905.21 by permitting Columbia Gas to withdraw natural-gas service without filing an abandonment application was unavailing; and (2) PUCO did not err in determining that Columbia Gas did not violate Ohio Rev. Code 4905.22’s prohibition against furnishing inadequate service. View "In re Complaints of Lycourt-Donovan v. Columbia Gas of Ohio, Inc." on Justia Law

When a juvenile whose parents are deceased appears at an amenability hearing, the juvenile is not required to ask for the appointment of a guardian ad litem (GAL). Rather, a GAL must be appointed as mandated by Ohio Rev. Code 2151.281(A)(1) and Juv. R. 4(B)(1). Further, the juvenile court’s failure to appoint a GAL in a delinquency proceeding is subject to criminal plain-error review if the juvenile does not object.After an amenability hearing, a judge concluded that Appellant, a juvenile, was not amenable to care and rehabilitation in the juvenile system and that Appellant was to be transferred to adult court. In common pleas court, Appellant pleaded guilty to one count of burglary, two counts of felonious assault, and one count of aggravated robbery, each including a firearm specification. On appeal, Appellant argued that the juvenile court committed plain error when it failed to appoint a GAL for his amenability hearing. The court of appeals concluded that the juvenile court erred in failing to appoint a GAL but that Appellant was unable to demonstrate prejudice. The Supreme Court affirmed, holding that Appellant failed to show that the juvenile court’s error in failing to appoint a GAL at the amenability hearing affected the outcome of the proceeding. View "State v. Morgan" on Justia Law