Justia Ohio Supreme Court Opinion Summaries

Appellant pleaded guilty to aggravated murder with firearm specifications. The court of appeals affirmed the conviction. Appellant later filed a petition for postconviction relief, which was denied. Appellant then made a request for additional discovery and filed motions to compel discovery. Appellant subsequently filed a petition in mandamus requesting a writ ordering the Hamilton County prosecutor to produce the discovery relevant to his case. The court of appeals dismissed the petition on the grounds that the issues raised in the petition had been decided on direct appeal and in the appeal of the denial of Appellant’s petition for postconviction relief. The Supreme Court affirmed, holding (1) the prosecutor had no legal duty to provide discovery, and Appellant had no legal right to discovery; and (2) Appellant had an adequate remedy in the ordinary course of law, precluding mandamus. View "State ex rel. Littlepage v. Deters" on Justia Law

Albany Commons Ltd., the owner of a 240-unit apartment complex, filed a complaint for tax year 2005 seeking a reduction from the auditor’s valuation of $13,600,000 to $9,720,000. At a hearing before the Franklin County Board of Revision (BOR), Albany Commons presented an appraisal by James Horner, a certified appraiser, that proposed a property valuation of $9,338,000. The BOR adopted Horner’s valuation. The Columbus City Schools Board of Education (BOE) appealed. The Board of Tax Appeals (BTA) adopted Horner’s appraisal valuation without adjustment and without discussion of other issues raised by the BOE. BOE again appealed, arguing that the absence of market data from the appraisal report and other flaws in the appraisal rendered the appraisal defective and unreliable. The Supreme Court affirmed, holding that the BOE did not establish an abuse of discretion in the BTA’s decision to credit Horner’s testimony and report. View "Columbus City Schools Board of Education v. Franklin County Board of Revision" on Justia Law

The tax commissioner, in a final determination journalized on June 8, 2010, reduced to $927,513 the almost $17 million amortizable amount that International Paper Company had reported. The tax commissioner’s letter to International Paper memorializing this determination was not mailed until July 12, 2010. The Board of Tax Appeals (BTA) reinstated International Paper’s amortizable amount, concluding that the tax commission violated Ohio Rev. Code 5751.53(D) by failing to notify International Paper of its assessment by the June 30 deadline. The tax commissioner appealed. The Supreme Court reversed, holding (1) Ohio Rev. Code 5751.53(D) requires that a reduction in the amortizable amount be embodied in a timely issued final determination to effect a reduction of the amortizable amount; (2) Ohio Rev. Code 5751.53(D) requires the tax commissioner to enter his determination on the journal by June 30, but the determination need not be mailed to the taxpayer by that date to be effective; (3) thus, the BTA erred by finding the tax commissioner’s final determination void; and (4) International Paper did not jurisdictionally forfeit any right to a remand for consideration of its substantive claim by failing to file a protective cross-appeal. Remanded for consideration of International Paper’s substantive challenge to the tax commissioner’s decision. View "International Paper Co. v. Testa" on Justia Law

In 1979, Appellant was convicted of aggravated burglary and attempted murder. In 2015, Appellant filed a motion to vacate the attempted-murder conviction. Judge John D. Sutula denied the motion. Thereafter, Appellant filed a petition for a writ of mandamus against Judge Sutula, arguing that the trial court lacked jurisdiction to convict him of attempted felony murder. The court of appeals granted summary judgment for Judge Sutula. The Supreme Court affirmed, holding (1) Appellant’s claim was without merit; and (2) Appellant could appeal the denial of his motion to vacate his sentence, which was sufficient to preclude a writ of mandamus. View "State ex rel. Williams v. Sutula" on Justia Law

In 2002, Appellant was indicted on one count of aggravated murder with firearm specifications. The jury did not find Appellant guilty of aggravated murder but found him guilty of the lesser offense of murder. In 2015, Appellant filed a petition for a writ of habeas corpus, arguing that the jury’s failing to find him guilty of aggravated murder was an acquittal barring the jury from finding him guilty of the lesser included offense of murder. The court of appeals dismissed Appellant’s petition, finding that Appellant had failed to comply with the mandatory requirements of Ohio Rev. Code 2969.25. The Supreme Court affirmed, holding (1) Appellant’s failure to satisfy section 2969.25(C)(1) required dismissal of his petition for a writ of habeas corpus; and (2) Appellant’s argument failed on the merits. View "State ex rel. Bates v. Eppinger" on Justia Law

In 1983, Appellant was convicted of aggravated murder, aggravated burglary, two counts of aggravated robbery, and two counts of felonious assault. Appellant’s convictions and sentences were affirmed on direct appeal. Throughout the years, Appellant filed various motions and petitions challenging his convictions. In this action, Appellant alleged that his sentence and conviction were void because there was no record “of a jury rendering verdict(s) on September 10, 1983” in his case. The court of appeals dismissed the action. The Supreme Court affirmed, holding (1) Appellant’s argument that the trial court lacked jurisdiction to convict him without a jury lacked merit; (2) Appellant had adequate remedies in the ordinary course of the law; and (3) Appellant’s timely failure to file an affidavit containing each civil action or appeal of a civil action that he had filed in the previous five years mandated dismissal of his petition. View "State ex rel. Walker v. Sloan" on Justia Law

In 2002, Appellant pleaded guilty to attempted murder and kidnapping. Appellant filed this action in mandamus seeking a writ ordering Cuyahoga County Common Pleas Court Judge David Matia to vacate his sentence under State v. Nolan and resentence him. The court of appeals granted summary judgment in favor of Judge Matia because Appellant was sentenced for attempted murder, not attempted felony murder, and therefore, Nolan did not apply. The Supreme Court affirmed the judgment of the court of appeals, holding that, under the facts of this case, Appellant was not entitled to a writ of mandamus. View "State ex rel. Tucker v. Matia" on Justia Law

In 2010, Plaintiffs filed a complaint in state court alleging medical malpractice and derivative claims against Defendants for medical care Plaintiffs received in 2008. Plaintiffs dismissed their claims without prejudice and, in 2012, filed a qui tam action in federal district court. In 2013, Plaintiffs moved for leave to file an amended complaint adding state law medical-malpractice claims. The federal district court denied leave and granted Defendants’ motion to dismiss. In 2013, Plaintiffs filed a complaint in state court alleging state malpractice claims. The trial court granted Defendants’ motion to dismiss the case, concluding that Plaintiffs failed to state a claim because both the statute of limitations and the statute of repose applicable to Plaintiffs’ claims had expired. The trial court further determined that 28 U.S.C. 1367(d), the federal tolling statute, applies only to protect claims while pending in federal court, and because Plaintiffs’ motion to amend the complaint to add the malpractice claims was denied, the state claims were never pending and were not protected. The court of appeals reversed, concluding that once a claim has vested, the statute of repose can no longer operate to bar litigation. The Supreme Court reversed, holding that the trial court appropriately dismissed the case because neither the saving statute nor the tolling statute applied in this case. View "Antoon v. Cleveland Clinic Foundation" on Justia Law

In 2009, Appellant was convicted of aggravated murder. The court of appeals affirmed. The amended death certificate listed the time of death as “morning,” as had been indicated in the original death certificate. In 2008, the coroner reexamined the case and estimated that the time of death was between “2:00 a.m. and 8:00 a.m.” In 2015, Appellant filed a habeas corpus petition claiming that his conviction was obtained by fraud and trickery because the coroner did not have authority to amend the victim’s death certificate or alter the estimated time of her death, and therefore, the trial court lacked jurisdiction to convict him. The Supreme Court affirmed, holding that Appellant failed to state a claim in habeas corpus because the coroner’s allegedly unlawful actions raised an evidentiary matter that could have been considered on direct appeal. View "State ex rel. Cutis v. Bunting" on Justia Law

After a trial, Appellant was found guilty of several offenses. Prior to trial, Appellant had filed a motion to represent himself, but the trial court never ruled on it. On appeal, Appellant, who was represented by appellate counsel, filed a supplemental pro se brief containing arguments regarding his motion for self-representation, but the supplemental brief was stricken because Appellant failed to comply with the page limitation set by the court, and the court of appeals did not rule on Appellant’s arguments regarding his self-representation motion. The court of appeals denied Appellant’s subsequent motion to reopen the appeal on the grounds that his appellate counsel had failed to rule that the trial court erred in not ruling on his motion for self-representation. Appellant then filed a complaint seeking a writ of mandamus compelling a ruling on his motion to represent himself. The court of appeals dismissed Appellant’s complaint. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of law by way of appeal. View "State ex rel. Cowan v. Gallagher" on Justia Law