Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals that granted a limited writ of mandamus ordering the Industrial Commission to amend its order awarding permanent-total-disability compensation to adjust the start date of the benefits awarded to Terry Phillips. Phillips suffered a workplace injury in 2011. In 2013, Phillips applied for permanent-total-disability compensation. After a hearing, a staff hearing officer concluded that Phillips was permanently and totally disabled based on the reports of Dr. Amol Soin, Dr. Steven Rosen, and Dr. Norman Berg. R&L Carriers Shared Services, LLC filed a complaint in mandamus arguing that the Commission’s order was not supported by the evidence. The magistrate recommended that the court of appeals issue a writ of mandamus ordering the Commission to amend its order to eliminate from consideration the reports of Dr. Soin and Dr. Rosen and to adjust the start date of the award to coincide with the date of Dr. Berg’s report. The court of appeals adopted the magistrate’s decision. The Supreme Court affirmed, holding that R&L failed to demonstrate that the Commission abused its discretion by entering an order not supported by some evidence in the record. View "State ex rel. R&L Carriers Shared Services, LLC v. Industrial Commission of Ohio" on Justia Law

The Supreme Court reversed the judgment of the court of appeals, which concluded that the consent of Appellant, the putative father of Child, to Child’s adoption by Appellees was not necessary because Appellant “willfully abandoned” the birth mother during her pregnancy and up to the time that the child was placed with Appellees. Specifically, the court held (1) Ohio Rev. Code 3107.07(B) does not equate the failure to care for and support the mother with willful abandonment of the mother; and (2) the probate court’s determination the Appellant willfully abandoned the mother was both contrary to the express language in section 3107.07(B)(2) (c) and against the manifest weight of the evidence. Because Appellees did not assert any other bases for the adoption to proceed without Appellant’s consent, the court remanded the matter to the probate court to vacate its adoption decree and to dismiss Appellees’ adoption petition. View "In re Adoption of P.L.H." on Justia Law

The Supreme Court vacated the decision of the Board of Tax Appeals (BTA) that retained the reduced values that the Franklin County Board of Revision (BOR) adopted for eighteen condominium parcels in Franklin County for tax years 2011 through 2013. The BTA upheld the BOR’s valuation on the grounds that it found no evidence to counter the BOR’s decision to modify the auditor’s original assessment of the property. The Supreme Court held (1) the BTA erred by relying on a presumption of validity rather than independently weighing the evidence; and (2) under recent case law, the reduced values ordered by the BOR were properly carried forward from tax year 2011 to tax years 2012 and 2013. View "Columbus City Schools Board of Education v. Franklin County Board of Revision" on Justia Law

Appellant was convicted of engaging in a pattern of corrupt activity and conspiracy for his role in plotting to kill several local officials. Defendant was sentenced to twenty years’ imprisonment. Appellant filed a petition for a writ of habeas corpus, arguing that his conviction and sentence for engaging in a pattern of corrupt activity were void because of an alleged defect in his indictment. The court of appeals dismissed the petition. The Supreme Court affirmed, holding (1) Appellant’s failure to attach to his petition an affidavit as required by Ohio Rev. Code 2969.25(A) warranted dismissal of his petition; and (2) Appellant’s claims were not cognizable in habeas corpus. View "State ex rel. Sands v. Bunting" on Justia Law

Defendant was convicted of felony murder. On appeal, Defendant did not challenge the sufficiency of the jury verdict forms. In postconviction proceedings, however, Defendant did raise an insufficient-verdict-form claim. Both of Defendant’s motions based on claims that the verdict forms were improper were denied. In the instant case, Defendant sought an order compelling the common pleas judge to vacate his sentence and issue a new judgment entry of sentence, arguing that the jury failed to sign the verdict forms for the predicate offense to his felony-murder conviction and, therefore, the jury failed to find him guilty of the necessary predicate offense to that charge, rendering his sentence for felony murder void. The common pleas judge denied relief. The Supreme Court affirmed, holding that Defendant had an adequate remedy in the ordinary course of law by way of his direct appeal, and Defendant’s mandamus claim was barred by res judicata. View "State ex rel. Love v. O'Donnell" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the nineteen-year prison sentence imposed on Defendant at resentencing for his involvement in the robberies of three individuals and the kidnapping of one of those individuals when Defendant was sixteen years old. Specifically, the court held (1) Defendant failed to show that the trial court imposed the sentence as a penalty for exercising his right to a jury trial instead of pleading guilty; (2) the sentence did not violate the Eighth Amendment because it did not involve the imposition of the harshest possible penalties for juveniles, it was proportionate, and there is no national consensus against imposing mandatory sentences on juveniles tried as adults; and (3) Defendant forfeited his argument that the mandatory sentencing scheme set forth in Ohio Rev. Code 2929 violates due process as applied to children. View "State v. Anderson" on Justia Law

Appellant, who was sentenced to a twelve-year term after he was arrested while on parole, filed a petition for a writ of habeas corpus, arguing that the Department of Rehabilitation and Correction improperly calculated his total sentence and violated his due process and equal protection rights by taking him into custody following his arrest without the “required on-site hearing.” The court of appeals dismissed the petition on the basis of res judicata. The Supreme Court affirmed, holding (1) the court of appeals erred by dismissing Appellant’s habeas corpus petition on the basis of res judicata because res judicata is not among the affirmative defenses that may be raised in a Ohio R. Civ. P. 12(B) motion to dismiss; but (2) Appellant’s petition was properly dismissed because it failed to state a claim. View "Johnson v. Moore" on Justia Law

Appellant, an inmate who was serving sentences imposed for his convictions for a variety of offenses, filed an original action in the court of appeals seeking monetary damages from the Madison County Court of Common Pleas, arguing that as a result of the sentence computation of the Bureau of Sentence Computation in the Ohio Department of Rehabilitation and Correction, he was serving for a second time one of the sentences imposed on him by the Madison County Court of Common Pleas, and therefore, he was entitled to damages for false imprisonment. The court of appeals dismissed the action. The Supreme Court affirmed, holding that the State of Ohio, not the common pleas court, was the party that should have been named in this action. View "Johnson v. Madison County Court of Common Pleas" on Justia Law

Any limitation on an arbitrator’s authority to modify a disciplinary action pursuant to a collective bargaining agreement (CBA) provision requiring that discipline be imposed only for just cause must be specifically bargained for by the parties and incorporated into the CBA.The common pleas court in this case vacated an arbitration award that changed the disciplinary sanction recommended by the chief of police against Sergeant David Hill of the Findlay Police Department from termination to a length suspension. The court of appeals affirmed, concluding that the arbitration award did not draw its essence from the CBA between the city of Findlay and the Ohio Patrolmen’s Benevolent Association and was arbitrary, capricious, and unlawful. The Supreme Court reversed, holding (1) because the CBA placed no limitation on the arbitrator’s authority to review the disciplinary action imposed and fashion a remedy, the arbitrator acted within his authority; and (2) the arbitrator’s award drew its essence from the CBA and was not arbitrary, capricious, or unlawful. View "Ohio Patrolmen's Benevolent Ass’n v. City of Findlay" on Justia Law

An Industrial Commission order determining that a preexisting condition that was substantially aggravated by a workplace injury has returned to a level that would have existed absent the jury is not appealable to a court of common pleas under Ohio Rev. Code 4123.512(A).Appellee suffered a workplace injury. Appellee’s claim for workers’ compensation was allowed for multiple conditions. The Bureau of Worker’s Compensation later moved to abate Appellee’s claim for substantial aggravated of preexisting dermatomyositis, asserting that Appellee’s dermatomyositis had returned to a level that would have existed without her workplace injury. A hearing officer granted the Bureau’s motion and ordered that compensation and medical benefits were no longer to be paid for the allowed condition. Appellee appealed. The trial court dismissed Appellee’s appeal for lack of jurisdiction, concluding that medical abatement of one condition of a claim is an extent-of-disability issue that cannot be appealed to a common pleas court under section 4123.512(A). The court of appeals reversed, concluding that the order was appealable to the court of common pleas. The Supreme Court reversed, holding that such a decision is not appealable under section 4123.512. Instead, a challenge to the Commission’s final decision regarding the extent of disability is properly made by an action in mandamus. View "Clendenin v. Girl Scouts of Western Ohio" on Justia Law