Justia Ohio Supreme Court Opinion Summaries

Plaintiff filed this action against Defendants seeking to quiet title to oil and gas rights under his surface lands and requesting a declaratory judgment, a permanent injunction, and compensation for conversion. The federal district court concluded that its ruling on the parties’ motions for summary judgment required a clarification of two areas of Ohio law and certified these questions to the Supreme Court. The Supreme Court answered (1) the 2006 version of the Dormant Mineral Act, rather than the 1989 version of the Act, applies to all claims asserted after June 30, 2006 alleging that the rights to minerals vested in the surface land holder prior to the 2006 amendments as a result of abandonment; and (2) a payment of a delay rental during the primary of an oil and gas lease is neither a title transaction nor a savings event under the Act. View "Corban v. Chesapeake Exploration, LLC" on Justia Law

Paul Bunting sought a writ of mandamus ordering Tuscarawas County Prosecuting Attorney Ryan Styer to prosecute Thomas Weaver for theft of a motorcycle. The court of appeals sua sponte dismissed the complaint after the prosecutor untimely filed a motion to dismiss. Bunting appealed. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion in dismissing the complaint because Styer’s failure to prosecute in this case was not an abuse of discretion, and therefore, Bunting did not have a clear legal right to a writ. View "State ex rel. Bunting v. Styer" on Justia Law

Appellant sought a writ of procedendo requiring Judge Kelly Cottrill to rule on his motion to vacate or set aside the judgment of his conviction. Judge Cottrill had ruled on Appellant’s motion but failed to issue findings of fact and conclusions of law. The court of appeals dismissed Appellant’s petition, finding that the petition was moot. The Supreme Court affirmed, holding that a writ of procedendo was inappropriate because Judge Cottrill did not refuse to enter judgment but, rather, Appellant was dissatisfied with the entry that she issued. View "State ex rel. Poulton v. Cottrill" on Justia Law

In 2016, Defendant was indicted of several offenses. Before trial, the prosecuting attorney obtained a second indictment. The trial court subsequently granted the State’s motion to dismiss the first indictment. Defendant then pleaded guilty to five counts of gross sexual imposition charged in the second indictment. Defendant filed a petition for a writ of habeas corpus arguing that the doctrine of res judicata precluded his convictions because his first indictment was dismissed with prejudice and included the same charges and was based on the same facts and circumstances as the second indictment. The court of appeals dismissed the petition, concluding that Defendant’s argument was a double jeopardy claim and that double jeopardy claims are not cognizable in habeas corpus. The Supreme Court affirmed, holding that because the first indictment was dismissed not on the merits but to prevent a double jeopardy violation, the doctrine of res judicata did not preclude Defendant’s convictions. View "State ex rel. Steele v. Eppinger" on Justia Law

In 2002, Defendant was indicted for murder. After a series of mistrials that were declared in Defendant’s case during the fourteen years since his arrest, Defendant moved to dismiss his indictment, alleging a violation of the Due Process and Double Jeopardy Clauses of the state and federal constitutions. The trial court denied the motion. The court of appeals affirmed, concluding that a mistrial or hung jury does not bar retrial or retrials. Defendant appealed, arguing that yet another trial would violate the “fair play” guaranteed by the Due Process Clause. The Supreme Court affirmed, holding (1) a double jeopardy challenge to the retrial of a defendant following a mistrial is analyzed under the Double Jeopardy Clause rather than the Due Process Clause; and (2) the Double Jeopardy Clause does not bar a defendant’s retrial after several mistrials have been properly declared. View "State v. Anderson" on Justia Law

After a jury trial, Defendant was convicted of murder and aggravated murder. After the mitigation phase and the jury recommendation, the trial court sentenced Defendant to death for the aggravated murder. Defendant appealed, raising twenty-one propositions of law. The Supreme Court rejected each of Defendant’s propositions and affirmed his convictions and sentence of death, holding (1) no prejudicial error occurred during the pretrial phase; (2) there was no prejudicial error in the trial court’s evidentiary rulings; (3) the jury instructions and verdict forms did not violate Defendant’s constitutional rights; (4) cumulative prosecutorial conduct did not violate Defendant’s due process rights; (5) trial counsel provided effective assistance; (6) nothing in the record supported Defendant’s claim of trial court bias; and (7) Defendant’s death sentence was proportionate and appropriate. View "State v. McKelton" on Justia Law

Relator submitted a public-records request to the records clerk for the police department of the City of Avon Lake relating to a police report about a skate-park incident. Relator claimed that he hand-delivered a written request to the clerk on December 30, 2014 and that the police department did not respond to the request until Relator filed this original action for a writ of mandamus on February 5, 2015. The department, in response, asserted that Relator never submitted a written request. The Supreme Court denied Relator’s request for a writ because the only documents requested but not produced no longer existed, and therefore, the case was moot. View "State ex rel. Pietrangelo v. Avon Lake" on Justia Law

Relators filed petitions proposing the adoption of county charters in Athens, Meigs, and Portage Counties. Each of the boards of elections reviewed the petitions and, while determining that the petitions contained sufficient signatures, rejected the petitions as invalid. Secretary of State Jon Husted denied Relators’ protests and instructed the boards not to place the proposed charters on the ballot. Relators then initiated this action seeking a writ of mandamus requiring Husted and the boards of elections to place the proposed charters on the ballot. The Supreme Court denied the writ, holding that the secretary of state and boards of elections did not abuse their discretion in determining that the proposed county charters failed to satisfy the requirements under Ohio Const. art. X, 3 for a valid charter initiative. View "State ex rel. Coover v. Husted" on Justia Law

In this mandamus action Relators sought a writ of mandamus to compel Secretary of State Jon Husted to restore more than 21,000 previously invalidated signatures in part-petitions supporting the Ohio Drug Price Relief Act. This action was a companion case to Ohio Mfrs. Ass’n v. Ohioans for Drug Price Relief Act, in which the Supreme Court found that the petition contained an insufficient number of signatures. In the instant case, the Supreme Court granted the requested writ in part and denied it in part, holding (1) the finding in Ohio Mfrs. Ass’n was based on the limited evidence before the Court in that case; (2) Husted is ordered to validate additional signatures from several counties, therefore establishing that the petition filing exceeded the minimum-signature threshold; and (3) Husted is ordered to rescind his transmission of the initiative to the General Assembly and is ordered instead to accept for verification the supplementary part-petitions, and if they are found to contain sufficient valid signatures, to place the matter on the November 2017 general-election ballot. View "State ex rel. Jones v. Husted" on Justia Law

In 2012, the Supreme Court affirmed an order of the Ohio Power Siting Board granting a certificate to Buckeye Wind, LLC to construct a wind farm in Champaign County. Buckeye subsequently filed an application to amend the certificate in part so that the wind farm could share portions of its facilities with another authorized wind farm. After a hearing, the Board approved Buckeye’s amendment. Champaign County and associated townships (collectively, the County) appealed, contending that the Board unlawfully approved the requested amendment without holding a hearing on all of the proposed changes in the amendment application. The Supreme Court affirmed, holding (1) the County forfeited its right to challenge the scope of the hearing on appeal; and (2) the Board acted reasonably and lawfully in limiting the scope of the hearing. View "In re Application of Buckeye Wind, LLC" on Justia Law