Justia Ohio Supreme Court Opinion Summaries

Appellant was the defendant in a criminal case in which he was found not guilty by reason of insanity and found to be a mentally ill person subject to hospitalization by court order. In 2014, Appellant filed a motion asserting that the trial court lacked authority to order his original commitment. The trial court denied relief, and Appellant appealed. In 2015, Appellant filed a motion to terminate his involuntary confinement. The trial court stayed the action pending the outcome of Appellant’s appeal from the denial of the 2014 motion. Thereafter, Appellant filed a petition for writs of mandamus and procedendo requesting that the trial court judge be ordered either to grant or hold a hearing on the 2015 motion. The court of appeals ultimately affirmed the trial court’s denial of the 2014 motion. In 2016, the court of appeals dismissed Appellant’s petition for writs of mandamus and procedendo, concluding that the request for a writ of procedendo was moot and that the judge had not abused his discretion in issuing the stay. The Supreme Court affirmed, holding that the case was moot, and the the trial court did not err in failing to consider the 2015 motion earlier. View "State ex rel. Rohrer v. Holzapfel" on Justia Law

Defendant, a legal resident of the United States, was indicted on two counts of robbery. Defendant admitted sufficient facts to warrant a finding of guilt in order to enroll in a diversion program. Defendant later moved to vacate his plea, arguing that his admission of guilt operated as a conviction under federal law and that the trial court erred by failing to provide him the advisement contained in Ohio Rev. Code 2943.031(A), which requires courts to alert noncitizens that a guilty plea or no-contest plea may affect their immigration status. The trial court denied Defendant’s motion. The court of appeals affirmed. The Supreme Court reversed, holding (1) section 2943.031(A) required the trial court to advise Defendant that his admission of guilt made for purposes of entering into the pretrial diversion program may affect his immigration status; and (2) because the trial court failed to give that advisement, the trial court must vacate the dismissal of the case against Defendant and vacate the admission of guilt executed as part of the pretrial diversion program process. Remanded. View "State v. Kona" on Justia Law

Mason Companies, Inc., a company based in Wisconsin, appealed from the imposition of Ohio’s commercial-activity tax (CAT) on revenue it earned from its sales of goods through orders received via telephone, mail, and the Internet. Mason challenged the imposition of the CAT assessments based on its being operated outside Ohio, employing no personnel in Ohio, and maintaining no facilities in Ohio. The Supreme Court upheld the CAT assessments against Mason, holding that, after applying the holding in Crutchfield Corp. v. Testa, the lack of Mason’s physical presence within Ohio was not a necessary condition for imposing the obligations of the CAT law given that the $500,000 sales-receipts threshold adequately assured that Mason’s nexus with Ohio was substantial. View "Mason Cos., Inc. v. Testa" on Justia Law

In this companion case to Crutchfield Corp. v. Testa, the Supreme Court considered Newegg, Inc.’s appeal from the imposition of Ohio’s commercial-activity tax (CAT) on revenue it earned from sales of computer-related products that it shipped into the state of Ohio. Newegg contested its CAT assessments based on its being operated outside Ohio, employing no personnel in Ohio, and maintaining no facilities in Ohio. In Crutchfield, the Supreme Court held that, under the Commerce Clause, the physical presence of an interstate business within Ohio is not a necessary condition for imposing the obligations of the CAT law given that the $500,000 sales receipts threshold adequately assures that the taxpayer’s nexus with Ohio is substantial. After applying Crutchfield’s holding in this case, the Supreme Court upheld the CAT assessments against Newegg. View "Newegg, Inc. v. Testa" on Justia Law

The tax commissioner issued commercial-activity tax (CAT) assessments against the Crutchfield Corporation on revenue it earned from sales of electronic products that it shipped from the state of Ohio. Crutchfield, whose business in Ohio consisted solely of shipping goods from outside the state to its consumers in Ohio using the United States Postal Service or common-carrier delivery services, challenged the issuance of CAT assessments against it, arguing that Ohio may not impose a tax on the gross receipts associated with its sales to Ohio consumers because Crutchfield lacks a “substantial nexus” with Ohio. Citing case law interpreting this substantial-nexus requirement, Crutchfield argued that its nexus to Ohio was not sufficiently substantial because it lacked a “physical presence” in Ohio. The Board of Tax Appeals (BTA) affirmed the assessments issued by the tax commissioner. The Supreme Court affirmed the decision of the BTA and upheld the CAT assessments against Crutchfield, holding (1) the physical presence requirement recognized by the United States Supreme Court for purposes of use-tax collection does not extend to business-privileges taxes such as the CAT; and (2) the statutory threshold of $500,000 of Ohio sales constitutes a sufficient guarantee of the substantiality of an Ohio nexus for purposes of the dormant Commerce Clause. View "Crutchfield Corp. v. Testa" on Justia Law

Scott and Dawn Smith (together, Insureds) filed an insurance claim with Erie Insurance Company (Insurer) seeking uninsured-motorist coverage as a result of injuries suffered by Scott in a no-contact accident allegedly caused by an unidentified vehicle. Insurer denied the claim. The trial court granted summary judgment to Insurer, concluding that a provision in the policy requiring Insureds to provide “independent corroborative evidence” that the unknown driver caused the injury meant that Insureds had to submit evidence, independent of Scott’s own testimony, corroborating that the accident was caused by an unknown motorist, and this they failed to do. The court of appeals reversed. The Supreme Court affirmed, holding that the policy’s requirement of independent corroborative evidence could be met using evidence derived from the insured’s testimony. View "Smith v. Erie Insurance Co." on Justia Law

In 2006, Inge Fox injured her left arm and hand in the course and scope of her employment with Manpower of Dayton, Inc. Fox’s workers’ compensation claim was allowed for several medical and psychological conditions. In 2013, Fox applied for permanent-total-disability compensation. The Industrial Commission granted the application, finding that Fox’s inability to work was based solely on the medical impairment caused by her allowed conditions. Manpower requested a writ of mandamus that would compel the Commission to vacate its award of permanent total disability compensation to Fox. The court of appeals denied the request. The Supreme Court affirmed, holding that Manpower failed to demonstrate that it was entitled to extraordinary relief in mandamus. View "State ex rel. Manpower of Dayton, Inc. v. Industrial Commission of Ohio" on Justia Law

Appellants in this case were Dr. Abubakar Atiq Durrani and several medical providers and hospitals. Plaintiffs in the underlying cases were more than fifty of Dr. Durrani’s former patients. Judge Robert Ruehlman of the Court of Common Pleas of Hamilton County was one of the twelve judges to whom the cases were originally assigned. Plaintiffs in the Durrani cases filed with Administrative Judge Robert Winkler a motion to transfer and consolidate the cases to the docket of Judge Ruehlman. Judge Ruehlman signed and entered the proposed consolidation order that Plaintiffs had submitted and sua sponte began signing entries of reassignment transferring the cases to his docket. Appellants filed a complaint for extraordinary relief seeking a writ of prohibition and writ of mandamus. The court of appeals dismissed the complaint. The Supreme Court reversed and issued a writ of mandamus and a writ of prohibition, holding (1) Appellants lacked an adequate remedy in the ordinary course of the law and had a clear legal right to have each underlying case returned to the judge to whom the case was originally assigned; and (2) Judge Ruehlman patently and unambiguously lacked the authority to order the consolidation of the underlying malpractice cases. View "State ex rel. Durrani v. Ruehlman" on Justia Law

Dynamic Industries, Inc. (DI) owned real property on which stood a building that DI claimed was unsalvageable. After an application was filed to have the building designated a historic landmark, DI filed an application seeking a permit to demolish the building. The City of Cincinnati did not process DI’s application because the historic-designation application was still pending. DI filed in the court of appeals an original action in mandamus seeking a peremptory writ compelling the City to immediately issue its requested permit and related relief. The City subsequently passed an ordinance approving the historic-designation application. When the building became a historic landmark, DI was precluded from obtaining a demolition permit unless it first obtained a certificate of appropriateness, for which DI did not apply. The court of appeals dismissed DI’s complaint. The Supreme Court affirmed, holding (1) the court of appeals lacked jurisdiction over DI’s claims in declaratory and injunctive relief and for money damages; and (2) DI failed to exhaust its administrative remedies before asserting its takings and general mandamus claims, and therefore, those claims were unripe and unavailing. View "State ex rel. Dynamic Industries, Inc. v. Cincinnati" on Justia Law

Defendant was convicted of two counts of aggravated and one count of murder in connection with the killing of Darian Polk. The trial court ordered the convictions merged for the purposes of sentencing. The State elected to have Defendant sentenced for the aggravated murder charged in count three. The trial court, however, imposed concurrent sentences on each of the three offenses instead of sentencing on only one offense. Defendant moved to correct his sentences, arguing that all of which convictions should be merged as allied offenses into a single conviction for aggravated murder. The trial court denied the motion, and the court of appeals affirmed. The Supreme Court modified the judgment of the appellate court to vacate the sentences imposed for murder in count one and aggravated murder in count two, holding (1) imposing separate sentences for allied offenses of similar import is contrary to law, and those sentences are void; (2) Defendant’s convictions were allied offenses of similar import; and (3) because the State designated one allied offense for sentencing, a remand for resentencing was not necessary in this case. View "State v. Williams" on Justia Law