Justia Ohio Supreme Court Opinion Summaries

After a jury trial, Defendant was convicted of eleven counts of aggravated murder, each containing death-penalty specifications. The trial court sentenced Defendant to death on each of the eleven counts. The Supreme Court affirmed, holding (1) courtroom closures did not deny Defendant his Sixth Amendment right to a public trial; (2) pretrial publicity did not deny Defendant a fair trial, and the trial court did not abuse its discretion by denying Defendant’s requests for a change of venue; (3) the trial court did not impermissibly restrict voir dire of prospective jurors or abuse its discretion in denying challenges for cause to a number of prospective jurors; (3) the trial court did not act arbitrarily by permitting jurors to use their initials to signify assent to verdicts; (4) Defendant’s arguments regarding the manner in which the death specifications were alleged in the indictment and with the instructions submitted to the jury were unavailing; (5) the trial court did not err in its instructions to the jury during the penalty phase; (6) Defendant’s counsel did not render ineffective assistance of counsel; (7) Defendant’s constitutional challenges to death penalty statutes failed; and (8) the death sentences in this case were appropriate and proportionate when compared with similar capital cases. View "State v. Sowell" on Justia Law

Appellees, a real estate investor and her company, filed a legal malpractice claim against Appellants, an attorney and his law firm, based on part on Appellants’ failure to assert a legal malpractice claim against third parties relating to Appellees’ purchase of a certain property. The trial court granted summary judgment in favor of Appellants on the potential malpractice claim. The court of appeals reversed. The Supreme Court reversed and reinstated the trial court’s grant of summary judgment in favor of Appellants, holding that no genuine issue of material fact existed with regard to the issue in this case and that Appellants did not agree to represent Appellees regarding their potential claim of legal malpractice against the third party relating to the purchase of the property at issue. View "Ratonel v. Roetzel & Andress, L.P.A." on Justia Law

In 1998, Appellee was sentenced to thirteen years in prison on various drug and weapons charges. The district court granted Appellee’s writ of habeas corpus and ordered the state to release Appellee or grant him a new trial within a certain time. The state did not retry Appellee, and the charges against him were dismissed with prejudice. Thereafter, Appellee filed a complaint seeking a determination that he was a wrongfully imprisoned individual. The trial court granted summary judgment in favor of the state. The court of appeals reversed. The Supreme Court reversed the judgment of the court of appeals and remanded with instructions to apply Mansaray v. State. On remand, the court of appeals again reversed the grant of summary judgment to the state, ruling that Appellee had satisfied all five elements of Ohio Rev. Code 2743.48(A). The Supreme Court reversed, holding that Appellee failed to satisfy all five elements of section 2743.48(A). View "James v. State" on Justia Law

During the course of grand jury proceedings, the state issued eight grand jury subpoenas seeking documents and testimony to individuals associated with Appellants. Appellants moved to quash the subpoenas, arguing that they required Appellants and their former attorneys to disclose information protected by the attorney-client privilege, the attorney work-product doctrine, and the common-interest doctrine. The trial court denied the motions. Appellants appealed the trial court’s order. The court of appeals dismissed the appeal for lack of a final order. The Supreme Court reversed, holding that an order denying a motion to quash a grand jury subpoena and ordering a party to testify or produce documents is a final order that may be appealed. Remanded. View "In re Grand Jury Proceedings of John Doe" on Justia Law

Darlene Burnham brought a personal injury action against the Cleveland Clinic and Cleveland Clinic Health System (collectively, Clinic). During discovery, Burnham requested certain documents that the Clinic alleged were not discoverable because they were shielded by the attorney-client privilege. Burnham filed a motion to compel discovery. The trial court granted the motion to compel. The Clinic appealed, arguing that the documents were protected by the attorney-client privilege and were not discoverable. The court of appeals dismissed the appeal for lack of jurisdiction, concluding that there was no final, appealable order to review because the Clinic had failed to establish that there would be prejudice resulting from disclosure of the documents. The Supreme Court reversed, holding (1) a discovery order compelling the production of documents allegedly protected by the attorney-client privilege is a final, appealable order subject to immediate review because such an order causes harm and prejudice that cannot be meaningfully remedied by a later appeal; and (2) because the Clinic has plausibly alleged that the attorney-client privilege would be breached by disclosure of the requested materials, the order compelling the disclosure is a final, appealable order. View "Burnham v. Cleveland Clinic" on Justia Law

Marilynne Earles was injured in the course and scope of her employment with BF Goodrich Company, Specialty Chemicals Division (Goodrich). Earles returned to work with certain restrictions. Later, Earles find an application for wage-loss compensation based on a reduction in her earnings while working in a light-duty position. A district hearing officer denied the application. A union representative subsequently filed an appeal on behalf of Earles. The Industrial Commission accepted the appeal and awarded wage-loss compensation. Goodrich filed a complaint in mandamus alleging that the Commission had abused its discretion. The court of appeals denied the writ. The Supreme Court affirmed, holding that the Commission did not abuse its discretion in (1) concluding that Earles’s wage loss was the direct result of her inability to return to her previous position due to the physical restrictions resulting from her claim; and (2) concluding that the appeal was timely filed. View "State ex rel. BF Goodrich Co., Specialty Chemicals Division v. Industrial Commission of Ohio" on Justia Law

The Cincinnati Enquirer requested the disclosure of recordings from cameras mounted on the dashboards of two Ohio State Highway Patrol (OSHP) cars. The OSHP denied the request in its entirety. The Enquirer subsequently filed this mandamus action alleging that the OSHP and Ohio Department of Public Safety (ODPS) violated the Ohio Public Records Act by refusing to release the recordings. Thereafter, ODPS provided copies of the recordings to the Enquirer. The Supreme Court held (1) subject to redaction, the Enquirer had a clear legal right to the requested records and that the defendants had a clear legal duty to provide the records; and (2) the Enquirer was not entitled to attorney fees, statutory damages, or court costs. View "State ex rel. Cincinnati Enquirer v. Ohio Department of Public Safety" on Justia Law

In 1995, Defendant was convicted of felonious assault on a police officer. After being released on parole, Defendant pleaded guilty in 2011 to resisting arrest, was given a suspended sentence, and was placed on community control. In 2013, Defendant stipulated to a violation of his community-control sanctions and was ordered to serve the sentence for the 2011 resisting-arrest conviction. In 2015, after Defendant had completed his resisting-arrest sentence, the parole board found that Defnedant had violated his parole for the 1995 sentence and imposed an additional term of confinement on that basis. Defendant filed this action in habeas corpus claiming that the board did not have authority to extend his incarceration. The court of appeals dismissed the action on the basis that Defendant failed to attach all his commitment papers to his petition. The Supreme Court affirmed on another ground, holding that Defendant failed to comply with the requirements of Ohio Rev. Code 2969.25 by filing an affidavit of indigence without attaching a statement of his inmate balance for each of the preceding six months. View "Robinson v. Miller" on Justia Law

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