Justia Ohio Supreme Court Opinion Summaries

In 2011, the Lucas County Court of Common Pleas convicted Appellant of two counts of vehicular assault. The judgment entry sentenced Appellant to a term of imprisonment and ordered him to “pay restitution in an amount to be determined at a hearing.” The court of appeals granted in part and denied in part the requested writs, holding that Appellant’s original sentencing entry was not a final, appealable order because it failed to specify the amount of restitution ordered as part of his sentence but that Appellant was not entitled to a de novo resentencing hearing to correct the error. Instead, the court ordered the trial court to issue a sentencing entry that constituted a final appealable order. The trial court subsequently entered a nunc pro tunc order correcting the 2011 entry by omitting the language in the 2011 entry ordering Appellant to pay restitution. Appellant appealed, arguing that he was entitled to a de novo resentencing hearing and that a nunc pro tunc entry cannot be issued to correct the error in the original sentencing entry. The Supreme Court affirmed, holding that Appellant failed to demonstrate that he had a clear legal right to a de novo resentencing hearing. View "State ex rel. Winfree v. McDonald" on Justia Law

In 2014, the juvenile court granted permanent custody of R.L., Appellant’s biological son, to the Hamilton County Job and Family Services (Family Services). In 2015, Appellant filed a second petition for writ of habeas corpus alleging that the Family Services director was unlawfully restraining R.L. pursuant to a juvenile court order. The director filed a motion to dismiss Appellant’s petition, alleging that the petition was successive and barred by res judicata and that Appellant had used alternative remedies at law to challenge the custody order. The court of appeals granted the motion to dismiss. The Supreme Court affirmed, holding that Appellant had, and had used, alternative remedies at law to challenge the juvenile court’s judgment granting permanent custody of R.L. to Family Services. View "Lee v. Weir" on Justia Law

Eleven captains and one battalion chief in the Cleveland Fire Department (collectively, Relators) alleged that each of them was eligible for promotion in the fire department but was deprived of the opportunity to take a competitive promotional examination. Relators filed this action in mandamus against the City of Cleveland and its mayor (collectively, Respondents) seeking immediate cessation of the noncompetitive examination process that the City was using for promotion within the fire department. The firefighters’ union challenged the noncompetitive examination process on the same grounds in a declaratory injunction action in the court of common pleas. The Supreme Court dismissed Relators’ action, holding that Relators had an adequate remedy in the ordinary course of law by way of intervening in the declaratory judgment case, precluding a writ of mandamus here. View "State ex rel. Schroeder v. Cleveland" on Justia Law

Appellant injured her knee while working, and a worker’s compensation claim was allowed for a medial meniscus tear of her right knee. When arthroscopic surgery was later performed on Appellant’s knee and no evidence of a meniscus tear was found, the Industrial Commission exercised its continuing jurisdiction and disallowed Appellant’s claim. Appellant filed a petition alleging that she was entitled to participate in the workers’ compensation system for her workplace injuries and also filed a complaint for a writ of mandamus alleging that the Commissioner’s denial of her claim was an abuse of discretion. The court of appeals denied the writ of mandamus. The Supreme Court affirmed, holding that Appellant had an adequate remedy by way of appeal, and therefore, the court of appeals lacked jurisdiction to issue a writ of mandamus. View "State ex rel. Carroll v. Galion Assisted Living, Ltd." on Justia Law

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