Justia Ohio Supreme Court Opinion Summaries

In State v. Gonzales (Gonzales I), the Supreme Court determined that, in prosecuting cocaine-possession offenses under Ohio Rev. Code 2925.11(C)(4)(b) through (f) involving mixed substances, the State must prove that the weight of the actual cocaine, excluding the weight of any filler materials, meets the statutory threshold. The State filed a motion for reconsideration, arguing that Gonzalez I was based on inconsistent application of the principles of statutory construction. The Supreme Court granted the motion for reconsideration, vacated its decision in Gonzalez I, and held that the entire mixture or compound, including any fillers that are part of the usable drug, must be considered for the purpose of determining the appropriate penalty for cocaine possession under section 2925.11(C)(4). View "State v. Gonzales" on Justia Law

In 1986, Appellant pleaded guilty to five counts of rape and six counts of complicity to rape. The trial court sentenced Appellant to four terms of life imprisonment and ordered that Appellant serve each of the life sentences consecutively. In 2015, Appellant filed a petition for a writ of habeas corpus arguing that the trial court acted outside its jurisdiction and improperly imposed the life terms because of errors in the sentencing entry. The court of appeals dismissed Appellant’s petition for a writ of habeas corpus. The Supreme Court affirmed, holding that Appellant’s habeas petition was properly dismissed because Appellant did not set forth a valid challenge to the jurisdiction of the sentencing court and because Appellant had an adequate remedy in the ordinary course of law to raise his sentencing errors. View "Dunkle v. Department of Rehabilitation & Correction" on Justia Law

In 2016, the Powell City Council approved an ordinance rezoning certain property from planned commercial and residence districts to downtown residence district. Thereafter, Brian Ebersole sought a writ of mandamus to compel Powell City Council to place the new ordinance on the May 2017 ballot. The Supreme Court denied the writ, holding that Ebersole was not entitled to a writ of mandamus because, under the city charter, the City had no clear legal duty to place the matter on the ballot. Therefore, Ebersole’s proper course of action was to challenge the validity of the ordinance by way of a suit for declaratory judgment, a form of relief that this Court had no original jurisdiction to grant. View "State ex rel. Ebersole v. City Council of Powell" on Justia Law

Relators were the members of the committee that nominated Gary Johnson and William Weld to appear on Ohio’s November 2016 ballot as independent candidates for president and vice president of the United States. Johnson and Weld jointly received 3.17 percent of the total votes cast in Ohio for president and vice president. Relators subsequently brought this action in mandamus seeking to require the Ohio Secretary of State to recognize Relators as a political party under Ohio Rev. Code 3517.01. The Supreme Court denied the writ, holding that Relators were not entitled to the writ because they do not qualify as a political party, as their candidates were nominated as independent candidates without any political-party affiliation, and section 3517.01 and Ohio Rev. Code 3501.01 permit only established political parties to retain ballot access if they receive at least three percent of the vote. View "State ex rel. Fockler v. Husted" on Justia Law

Plaintiff was injured in a motor vehicle accident allegedly caused by a high-speed police chase. Appellant filed a negligence action against certain police officers, alleging that the officers engaged in a high-speed case of a suspect that ended when Barnhart’s vehicle struck Plaintiff’s vehicle, killing the suspect and seriously injuring Plaintiff. The trial court granted summary judgment in favor of the officers, concluding (1) as a matter of law, a police officer who pursues a suspect is not the proximate cause of injuries to a third party unless the officer’s conduct is extreme and outrageous; and (2) under this standard, no reasonable juror could conclude that the officers’ actions were the proximate cause of the accident. The Court of Appeals affirmed. The Supreme Court affirmed, albeit on different grounds, holding (1) the no-proximate-cause standard applied by the court of appeals in this case is contrary to the express dictates of Ohio Rev. Code 2744.03(A)(6)(b), which provides that law enforcement officers are immune from liability unless they act maliciously, in bad faith, or in a wanton or reckless manner; and (2) applying the correct standard set forth in section 2744.03(A)(6)(b), the officers could not be held liable for damages as a result of their actions. View "Argabrite v. Neer" on Justia Law

Jill Stevenson failed to stop at a stop sign at an intersection and collided with Gary Bibler. A police officer determined that the stop sign was significantly obstructed from a distance as a driver approached it. Bibler and his wife, Yvonne Bibler, filed a complaint alleging that Stevenson was negligent for failing to stop and that the City of Findlay was negligent for failing to ensure that the stop sign was visible. The trial court dismissed Findlay from the case, concluding that the City was entitled to statutory political subdivision immunity and that an exception to immunity did not apply in this case. The Biblers and Stevenson subsequently settled, and the Biblers appealed the grant of summary judgment in favor of Findlay. The Supreme Court reversed, holding that the City was not immune pursuant to Ohio Rev. Code 2744.02(B)(3) and was potentially amenable to liability. Remanded. View "Bibler v. Stevenson" on Justia Law

Matthew Shaughnessy, an attorney who requests and reviews police incident reports, alleged that, on five different occasions, the City of Cleveland failed to produce copies of police incident reports in a reasonable amount of time, which he contended was eight business days. Shaughnessy asked the Supreme Court to order the City to respond to future requests within eight business days and also requested $1,000 in statutory damages. The Supreme Court denied the request for relief and the request for statutory damages, holding that Shaughnessy failed to show that the City had a clear legal city to produce, or that he had a clear legal right to receive, the requested records within eight business days. View "State ex rel. Shaughnessy v. City of Cleveland" on Justia Law

Employee was terminated from his employment after failing a routine drug test administered soon after a workplace accident in which he was injured. Employee’s drug use did not cause the accident. Employee’s workers’ compensation claim was initially allowed for temporary total disability (TTD) compensation. However, the Industrial Commission subsequently determined that Employee voluntarily abandoned his employment by using marijuana prior to the accident and was therefore not eligible for TTD compensation. Employee petitioned for a writ of a mandamus compelling the Commission to vacate its order denying TTD compensation and to issue an order granting Employee TTD compensation. The court of appeals granted the writ. The Supreme Court affirmed, holding that when an employee is terminated after a workplace injury for conduct prior to and unrelated to the injury, the employee’s termination does not amount to a voluntary abandonment of employment for purposes of TTD compensation when (1) the discovery of the dischargeable offense occurred because of the injury; and (2) the employee was medically incapable of returning to work as a result of the workplace injury at the time of the termination. View "State ex rel. Cordell v. Pallet Companies" on Justia Law

Defendant was charged with operating a vehicle while under the influence (OVI) of a drug of abuse. After a trial, Defendant was convicted. The court of appeals vacated the trial court’s judgment, finding that the evidence was insufficient to support Defendant’s OVI conviction because there was no evidence to connect Defendant’s use of hydrocodone, a widely known drug of abuse, with his impairment. Therefore, the appellate court concluded that expert testimony was necessary to support the OVI conviction. The Supreme Court reversed, holding that the evidence was sufficient to support the OVI conviction and that no expert testimony was required to link the ingestion of hydrocodone with Defendant’s impairment. View "State v. Richardson" on Justia Law

Ross Linert sustained severe injuries when Adrien Foutz, an intoxicated driver, struck Ross’s vehicle from behind, triggering a fuel-fed fire. At the time of the accident, Ross, a veteran police officer, was on patrol in a 2005 Crown Victoria Police Interceptor (CVPI) manufactured by Ford Motor Company. Ross and his wife, Brenda Linert, sued Foutz. The Linerts subsequently added product liability and malice claims against Ford. The jury returned a verdict in favor of Ford on all of the Linerts’ claims. The Linerts appealed, arguing that the trial court erred in failing to instruct the jury on Ohio Rev. Code 2307.76(A)(2), Ohio’s statute governing manufacturers’ postmarked duty to warn consumers of risks associated with a product that are not discovered until after the product has been sold. The appellate court ordered a new trial on the Linerts’ postmarketing failure-to-warn claim, concluding that the there was sufficient evidence to warrant a jury instruction on the Linerts’ postmarketing failure-to-warn claim. The Supreme Court reversed, holding that the trial court properly refused to instruct on a postmarketing duty to warn in this case. View "Linert v. Foutz" on Justia Law