Justia Ohio Supreme Court Opinion Summaries

A complaint was filed in the juvenile court alleging that Appellant engaged in conduct that would be considered aggravated robbery if committed by an adult. Appellant was sixteen years old at the time of the alleged offense. The State filed a motion to transfer Appellant to the general division of the common pleas court to be tried as an adult pursuant to Ohio Rev. Code 2152.10(A)(2)(b) and 2152.12(A)(1)(b), which provide for mandatory transfer of juveniles to adult court in certain circumstances. After a hearing, the juvenile court automatically transferred the case. Appellant moved to dismiss the ensuring indictment charging him with two counts of aggravated robbery with accompanying firearm specifications and transfer his case back to juvenile court, arguing that mandatory transfer of juveniles is unconstitutional. The trial court overruled the motion. Appellant subsequently entered pleas of no contest to the two counts of aggravated robbery. The court of appeals affirmed. The Supreme Court reversed, holding that mandatory transfer of juveniles to adult court without providing for the protection of a discretionary determination by the juvenile court judge violates juveniles’ right to due process. View "State v. Aalim" on Justia Law

After a jury trial, Appellant was found guilty of two counts of murder. The trial court sentenced Appellant to death. The Supreme Court affirmed. Appellant later filed an amended application for postconviction DNA testing pursuant to Ohio Rev. Code 2953.71 through 2953.84. The county common pleas court denied the application. Appellant appealed, arguing that section 2953.73(E)(1) violates the Eighth and Fourteenth Amendments because it discriminates between capital and non-capital criminal defendants, fails to provide appellate review, and results in the arbitrary and capricious application of the death penalty. The Supreme Court held (1) section 2953.73(E)(1) violates the constitutional right to equal protection, but the unconstitutional portion of the statute can be excised to create a constitutionally sound procedure that provides capital offenders an appeal of right to the Supreme Court; and (2) this constitutional analysis applies equally to section 2953.72(A)(8), which summarizes the procedure for appealing a denial of postconviction DNA testing. Therefore, the Court applied the severance remedy to the unconstitutional portions of the statutes. Consequently, Appellant will be permitted an appeal of right to the Supreme Court from the denial of his amended application for postconviction DNA testing. View "State v. Noling" on Justia Law

Mother gave birth to a child while serving a prison sentence. Crawford County Department of Job and Family Services (the Agency) filed a complaint requesting permanent custody of the child. The juvenile court terminated Mother’s parental rights to the child and granted permanent custody to the Agency. Mother appealed, arguing that the Agency did not make a good-faith effort to reunify her with child because the child could have been placed with a relative as a substitute caregiver when the Agency had temporary custody of the child. The court of appeals affirmed, holding that the testimony presented at the permanent-custody hearing provided an appropriate basis for rejecting the relative as a relative caregiver. The Supreme Court affirmed, holding that the trial court did not abuse its discretion in not finding error in the Agency’s decision to deny the relative at issue as a substitute caregiver. View "In re A.J." on Justia Law

Relators filed this original action in mandamus seeking the release of video from a camera worn by an officer who shot a motorist after a traffic stop. Relators asserted that Respondent, the prosecuting attorney, violated the Public Records Act by failing either to make the body-camera video available for inspection and copying or to prove that it was exempt from disclosure. The prosecutor released the video two days after the complaint was filed. The Supreme Court dismissed the writ of mandamus as to certain relators because the relators failed to request the record from the prosecutor’s office and denied the writ as to other relators because the body-camera video had already been produced. Because the video was produced within a reasonable amount of time, the request for statutory damages and attorney fees was also denied. View "State ex rel. Cincinnati Enquirer v. Deters" on Justia Law

Appellee pled guilty to a fourth-degree-felony charge of receiving stolen property. The trial court sentenced Appellee to two years of community control and required him to comply with the court’s standard community-control conditions and to pay court costs and probation fees. The trial court later found that Appellee had failed to abide by the requirements of community control. After a hearing, the trial court terminated community control and sentenced Appellee to an eighteen-month prison sentence. Appellee appealed, arguing that the court erred by imposing a sentence without asking him if he wished to exercise his right to allocution. The court of appeals remanded for resentencing, holding that Ohio R. Crim. P. 32(A) and Ohio Rev. Code 2929.19(A) entitled Appellee to make a statement in mitigation of his punishment and that the error was not harmless. The Supreme Court affirmed, holding that a trial court must afford an offender an opportunity for allocution at a community-control-revocation hearing before imposing a sentence for violating the conditions of community control. View "State v. Jackson" on Justia Law

After a jury trial, Defendant was convicted of two counts of aggravated murder, among other crimes. Defendant was sentenced to death. The Supreme Court affirmed Defendant’s convictions and sentence, holding (1) defense counsel’s absences did not violate Defendant’s rights to counsel or due process; (2) the trial court did not violate Defendant’s rights to due process and a fair trial when it denied his motion for relief from prejudicial joinder; (3) trial counsel did not provide ineffective assistance with regard to two suppression issues; (4) no prejudicial error occurred with how the jury view was conducted; (5) no prejudicial error occurred with regard to the evidence submitted at trial; (6) the trial court did not err by denying Defendant’s Ohio R. Crim. P. 29 motion; (7) no prejudicial error occurred during the sentencing phase of trial; and (8) Defendant death sentence was appropriate and proportional. View "State v. Spaulding" on Justia Law

In 2011, the Lucas County Court of Common Pleas convicted Appellant of two counts of vehicular assault. The judgment entry sentenced Appellant to a term of imprisonment and ordered him to “pay restitution in an amount to be determined at a hearing.” The court of appeals granted in part and denied in part the requested writs, holding that Appellant’s original sentencing entry was not a final, appealable order because it failed to specify the amount of restitution ordered as part of his sentence but that Appellant was not entitled to a de novo resentencing hearing to correct the error. Instead, the court ordered the trial court to issue a sentencing entry that constituted a final appealable order. The trial court subsequently entered a nunc pro tunc order correcting the 2011 entry by omitting the language in the 2011 entry ordering Appellant to pay restitution. Appellant appealed, arguing that he was entitled to a de novo resentencing hearing and that a nunc pro tunc entry cannot be issued to correct the error in the original sentencing entry. The Supreme Court affirmed, holding that Appellant failed to demonstrate that he had a clear legal right to a de novo resentencing hearing. View "State ex rel. Winfree v. McDonald" on Justia Law

In 2014, the juvenile court granted permanent custody of R.L., Appellant’s biological son, to the Hamilton County Job and Family Services (Family Services). In 2015, Appellant filed a second petition for writ of habeas corpus alleging that the Family Services director was unlawfully restraining R.L. pursuant to a juvenile court order. The director filed a motion to dismiss Appellant’s petition, alleging that the petition was successive and barred by res judicata and that Appellant had used alternative remedies at law to challenge the custody order. The court of appeals granted the motion to dismiss. The Supreme Court affirmed, holding that Appellant had, and had used, alternative remedies at law to challenge the juvenile court’s judgment granting permanent custody of R.L. to Family Services. View "Lee v. Weir" on Justia Law

Eleven captains and one battalion chief in the Cleveland Fire Department (collectively, Relators) alleged that each of them was eligible for promotion in the fire department but was deprived of the opportunity to take a competitive promotional examination. Relators filed this action in mandamus against the City of Cleveland and its mayor (collectively, Respondents) seeking immediate cessation of the noncompetitive examination process that the City was using for promotion within the fire department. The firefighters’ union challenged the noncompetitive examination process on the same grounds in a declaratory injunction action in the court of common pleas. The Supreme Court dismissed Relators’ action, holding that Relators had an adequate remedy in the ordinary course of law by way of intervening in the declaratory judgment case, precluding a writ of mandamus here. View "State ex rel. Schroeder v. Cleveland" on Justia Law

Appellant injured her knee while working, and a worker’s compensation claim was allowed for a medial meniscus tear of her right knee. When arthroscopic surgery was later performed on Appellant’s knee and no evidence of a meniscus tear was found, the Industrial Commission exercised its continuing jurisdiction and disallowed Appellant’s claim. Appellant filed a petition alleging that she was entitled to participate in the workers’ compensation system for her workplace injuries and also filed a complaint for a writ of mandamus alleging that the Commissioner’s denial of her claim was an abuse of discretion. The court of appeals denied the writ of mandamus. The Supreme Court affirmed, holding that Appellant had an adequate remedy by way of appeal, and therefore, the court of appeals lacked jurisdiction to issue a writ of mandamus. View "State ex rel. Carroll v. Galion Assisted Living, Ltd." on Justia Law