Justia Ohio Supreme Court Opinion Summaries

Jessica Simpkins and her father, Gene Simpkins, (together, Appellants) sued Grace Brethren Church of Delaware, Ohio for negligent hiring, retention, and supervision of Brian Williams, a senior pastor at Sunbury Grace Brethren Church who forced oral and vaginal intercourse with Simpkins, then a fifteen-year-old parishioner. The jury found that Simpkins was entitled to $3,651,378 in compensatory damages, which included past and future economic damages and past and future noneconomic damages. The trial court applied the cap in Ohio Rev. Code 2315.18(B)(2) to reduce Simpkins’s noneconomic damages from $3.5 million to $350,000. The court of appeals rejected Appellants’ constitutional challenges to section 2315.18(B)(2) as well as their argument that Simpkins’s noneconomic damages arose out of two occurrences for purposes of applying the damage caps. The Supreme Court affirmed, holding (1) section 2315.18(B) is constitutional as applied to the facts in this case; and (2) this case involved a single “occurrence” for purposes of applying the damage caps. View "Simpkins v. Grace Brethren Church of Delaware, Ohio" on Justia Law

Appellee was an eighteen-year-old high school student when he allegedly committed criminal acts that led to his conviction of attempted robbery and attempted complicity in the commission of intimidation. Appellee later applied to the trial court to seal the records pertaining to his conviction. The State argued that Ohio Rev. Code 2953.36 prohibiting the sealing of the record of Appellee’s conviction because the statute prohibits the sealing of records of convictions of an offense of violence when the offense is a felony. The trial court denied Appellee’s application. The court of appeals reversed. The Supreme Court reversed, holding that attempted robbery is a crime of violence and that, pursuant to section 2953.36, a person convicted of attempted robbery is ineligible to have the record of that conviction sealed. View "State v. V.M.D." on Justia Law

After a jury trial, Appellant was convicted of aggravated murder and other offenses. The trial court sentenced Appellant to death for the murder conviction. The Supreme Court affirmed Appellant’s convictions and sentence, holding (1) the trial court did not err in admitting statements Appellant made during his interview with police; (2) Appellant did not receive ineffective assistance of counsel during voir dire or during trial; (3) the trial court did not err by failing to hold a hearing to determine a witness’s competency to testify; (4) the trial judge was not biased against Appellant, and the trial judge did not err by refusing to grant a mistrial for the judge’s alleged biased interjections; (5) Appellant failed to establish plain error regarding the prosecutor’s closing statements; and (6) Appellant’s sentence was appropriate and proportional. View "State v. Cepec" on Justia Law

Betty Lunn, the owner of a single-family residence, challenged the Lorain County auditor’s valuation of the property for tax year 2012. Lunn appealed, arguing that her 2011 purchase of the home was a recent arm’s-length sale that established a lower true value. The Board of Revision (BOR) retained the auditor’s valuation, concluding that the auditor had provided insufficient evidence of the sale. The Board of Tax Appeals (BTA) reversed and valued the property according to the sale price. The Supreme Court reversed, holding (1) the BTA acted reasonably and lawfully when it found that Lunn satisfied her initial burden to show a recent arm’s-length sale under former Ohio Rev. Code 4713.03; but (2) Lunn’s purchase was a “forced sale” under section 5713.04, and therefore, Lunn failed to overcome the presumption that the sale of the property post-foreclosure was not indicative of the property’s true value. View "Lunn v. Lorain County Board of Revision" on Justia Law

Cynthia Musto owned property that the Lorain County auditor valued at $547,260 for the tax year 2012. Musto filed a complaint requesting a reduction in value to $405,000. The Board of Revision (BOR) retained the county auditor’s valuation of Musto’s property. The Board of Tax Appeals (BTA) affirmed. The Supreme Court affirmed the BTA’s decision, holding (1) the BTA did not err by denying Musto’s motion to continue the BTA hearing; (2) the BTA reasonably and lawfully retained the auditor’s valuation because Musto did not present clear evidence negating it; and (3) the BTA did not err by denying Musto’s motion to disqualify counsel for the auditor and the BOR. View "Musto v. Lorain County Board of Revision" on Justia Law

Appellee was injured at work. The Industrial Commission awarded Appellee permanent total disability compensation benefits, concluding that Appellee was unable to perform any sustained remunerative employment due solely to the medical impairment caused by the allowed psychological condition in her workers’ compensation claim. Appellee subsequently applied for permanent partial disability compensation, arguing that she was entitled to this award based on the physical conditions allowed in her claim. The Industrial Commission determined that a claimant is not barred from concurrent compensation for permanent partial disability if it is based on conditions that were not the basis for the prior finding of permanent total disability in the same claim. Appellant, Appellee’s employer, filed a complaint seeking a writ of mandamus to compel the Commission to vacate its order. The court of appeals denied the writ. The Supreme Court reversed and granted Appellant’s request for a writ of mandamus, holding that the Commission has no authority to award an injured worker permanent partial disability compensation when the worker has been previously found to be permanently disabled in the same claim, even when the new finding is based on conditions in the claim that formed no part of the basis for the prior finding of permanent total disability. View "State ex rel. Ohio Presbyterian Retirement Services, Inc. v. Industrial Commission" on Justia Law

After a jury trial, Defendant was convicted of eleven counts of aggravated murder, each containing death-penalty specifications. The trial court sentenced Defendant to death on each of the eleven counts. The Supreme Court affirmed, holding (1) courtroom closures did not deny Defendant his Sixth Amendment right to a public trial; (2) pretrial publicity did not deny Defendant a fair trial, and the trial court did not abuse its discretion by denying Defendant’s requests for a change of venue; (3) the trial court did not impermissibly restrict voir dire of prospective jurors or abuse its discretion in denying challenges for cause to a number of prospective jurors; (3) the trial court did not act arbitrarily by permitting jurors to use their initials to signify assent to verdicts; (4) Defendant’s arguments regarding the manner in which the death specifications were alleged in the indictment and with the instructions submitted to the jury were unavailing; (5) the trial court did not err in its instructions to the jury during the penalty phase; (6) Defendant’s counsel did not render ineffective assistance of counsel; (7) Defendant’s constitutional challenges to death penalty statutes failed; and (8) the death sentences in this case were appropriate and proportionate when compared with similar capital cases. View "State v. Sowell" on Justia Law

Appellees, a real estate investor and her company, filed a legal malpractice claim against Appellants, an attorney and his law firm, based on part on Appellants’ failure to assert a legal malpractice claim against third parties relating to Appellees’ purchase of a certain property. The trial court granted summary judgment in favor of Appellants on the potential malpractice claim. The court of appeals reversed. The Supreme Court reversed and reinstated the trial court’s grant of summary judgment in favor of Appellants, holding that no genuine issue of material fact existed with regard to the issue in this case and that Appellants did not agree to represent Appellees regarding their potential claim of legal malpractice against the third party relating to the purchase of the property at issue. View "Ratonel v. Roetzel & Andress, L.P.A." on Justia Law

In 1998, Appellee was sentenced to thirteen years in prison on various drug and weapons charges. The district court granted Appellee’s writ of habeas corpus and ordered the state to release Appellee or grant him a new trial within a certain time. The state did not retry Appellee, and the charges against him were dismissed with prejudice. Thereafter, Appellee filed a complaint seeking a determination that he was a wrongfully imprisoned individual. The trial court granted summary judgment in favor of the state. The court of appeals reversed. The Supreme Court reversed the judgment of the court of appeals and remanded with instructions to apply Mansaray v. State. On remand, the court of appeals again reversed the grant of summary judgment to the state, ruling that Appellee had satisfied all five elements of Ohio Rev. Code 2743.48(A). The Supreme Court reversed, holding that Appellee failed to satisfy all five elements of section 2743.48(A). View "James v. State" on Justia Law

During the course of grand jury proceedings, the state issued eight grand jury subpoenas seeking documents and testimony to individuals associated with Appellants. Appellants moved to quash the subpoenas, arguing that they required Appellants and their former attorneys to disclose information protected by the attorney-client privilege, the attorney work-product doctrine, and the common-interest doctrine. The trial court denied the motions. Appellants appealed the trial court’s order. The court of appeals dismissed the appeal for lack of a final order. The Supreme Court reversed, holding that an order denying a motion to quash a grand jury subpoena and ordering a party to testify or produce documents is a final order that may be appealed. Remanded. View "In re Grand Jury Proceedings of John Doe" on Justia Law