Justia Ohio Supreme Court Opinion Summaries

In 2002, Appellant was indicted on one count of aggravated murder with firearm specifications. The jury did not find Appellant guilty of aggravated murder but found him guilty of the lesser offense of murder. In 2015, Appellant filed a petition for a writ of habeas corpus, arguing that the jury’s failing to find him guilty of aggravated murder was an acquittal barring the jury from finding him guilty of the lesser included offense of murder. The court of appeals dismissed Appellant’s petition, finding that Appellant had failed to comply with the mandatory requirements of Ohio Rev. Code 2969.25. The Supreme Court affirmed, holding (1) Appellant’s failure to satisfy section 2969.25(C)(1) required dismissal of his petition for a writ of habeas corpus; and (2) Appellant’s argument failed on the merits. View "State ex rel. Bates v. Eppinger" on Justia Law

In 1983, Appellant was convicted of aggravated murder, aggravated burglary, two counts of aggravated robbery, and two counts of felonious assault. Appellant’s convictions and sentences were affirmed on direct appeal. Throughout the years, Appellant filed various motions and petitions challenging his convictions. In this action, Appellant alleged that his sentence and conviction were void because there was no record “of a jury rendering verdict(s) on September 10, 1983” in his case. The court of appeals dismissed the action. The Supreme Court affirmed, holding (1) Appellant’s argument that the trial court lacked jurisdiction to convict him without a jury lacked merit; (2) Appellant had adequate remedies in the ordinary course of the law; and (3) Appellant’s timely failure to file an affidavit containing each civil action or appeal of a civil action that he had filed in the previous five years mandated dismissal of his petition. View "State ex rel. Walker v. Sloan" on Justia Law

In 2002, Appellant pleaded guilty to attempted murder and kidnapping. Appellant filed this action in mandamus seeking a writ ordering Cuyahoga County Common Pleas Court Judge David Matia to vacate his sentence under State v. Nolan and resentence him. The court of appeals granted summary judgment in favor of Judge Matia because Appellant was sentenced for attempted murder, not attempted felony murder, and therefore, Nolan did not apply. The Supreme Court affirmed the judgment of the court of appeals, holding that, under the facts of this case, Appellant was not entitled to a writ of mandamus. View "State ex rel. Tucker v. Matia" on Justia Law

In 2010, Plaintiffs filed a complaint in state court alleging medical malpractice and derivative claims against Defendants for medical care Plaintiffs received in 2008. Plaintiffs dismissed their claims without prejudice and, in 2012, filed a qui tam action in federal district court. In 2013, Plaintiffs moved for leave to file an amended complaint adding state law medical-malpractice claims. The federal district court denied leave and granted Defendants’ motion to dismiss. In 2013, Plaintiffs filed a complaint in state court alleging state malpractice claims. The trial court granted Defendants’ motion to dismiss the case, concluding that Plaintiffs failed to state a claim because both the statute of limitations and the statute of repose applicable to Plaintiffs’ claims had expired. The trial court further determined that 28 U.S.C. 1367(d), the federal tolling statute, applies only to protect claims while pending in federal court, and because Plaintiffs’ motion to amend the complaint to add the malpractice claims was denied, the state claims were never pending and were not protected. The court of appeals reversed, concluding that once a claim has vested, the statute of repose can no longer operate to bar litigation. The Supreme Court reversed, holding that the trial court appropriately dismissed the case because neither the saving statute nor the tolling statute applied in this case. View "Antoon v. Cleveland Clinic Foundation" on Justia Law

In 2009, Appellant was convicted of aggravated murder. The court of appeals affirmed. The amended death certificate listed the time of death as “morning,” as had been indicated in the original death certificate. In 2008, the coroner reexamined the case and estimated that the time of death was between “2:00 a.m. and 8:00 a.m.” In 2015, Appellant filed a habeas corpus petition claiming that his conviction was obtained by fraud and trickery because the coroner did not have authority to amend the victim’s death certificate or alter the estimated time of her death, and therefore, the trial court lacked jurisdiction to convict him. The Supreme Court affirmed, holding that Appellant failed to state a claim in habeas corpus because the coroner’s allegedly unlawful actions raised an evidentiary matter that could have been considered on direct appeal. View "State ex rel. Cutis v. Bunting" on Justia Law

After a trial, Appellant was found guilty of several offenses. Prior to trial, Appellant had filed a motion to represent himself, but the trial court never ruled on it. On appeal, Appellant, who was represented by appellate counsel, filed a supplemental pro se brief containing arguments regarding his motion for self-representation, but the supplemental brief was stricken because Appellant failed to comply with the page limitation set by the court, and the court of appeals did not rule on Appellant’s arguments regarding his self-representation motion. The court of appeals denied Appellant’s subsequent motion to reopen the appeal on the grounds that his appellate counsel had failed to rule that the trial court erred in not ruling on his motion for self-representation. Appellant then filed a complaint seeking a writ of mandamus compelling a ruling on his motion to represent himself. The court of appeals dismissed Appellant’s complaint. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of law by way of appeal. View "State ex rel. Cowan v. Gallagher" on Justia Law

At issue in this case was the proper valuation for the tax year 2010 of an undeveloped tract made up of three noncontiguous parcels that was purchased in 2007 for the development of ranch condominiums. The county auditor originally valued the entire tract using the 2007 sale price, with a portion of that price allocated to each of the individual parcels. The Delaware County Board of Revision ordered reductions based on a deputy auditor’s report that was not made part of the record until the case was appealed. The Board of Tax Appeals (BTA) retained the reduced valuations. The Supreme Court vacated the BTA’s decision, holding that the evidence in the record negates the validity of the 2007 sale price but does not clearly establish an alternative valuation for the property. Remanded with instructions that the BTA perform an independent valuation of the property based on the existing record and any additional evidence that may be heard or received. View "Olentangy Local Schools Board of Education v. Delaware County Board of Revision" on Justia Law

M.S., a minor child, was in the temporary custody of the Allen County Children Services Board by order of the Juvenile Division of the Allen County Common Pleas Court. At that time, the Allen County Children Services Board brought this action seeking a writ of prohibition barring the Probate Division of the Mercer County Common Pleas Court and two judges from exercising jurisdiction over M.S. Both the Probate Court and the Juvenile Court asserted jurisdiction over the child’s residential placement. The Supreme Court granted a peremptory writ of prohibition precluding the Probate Court from exercising jurisdiction. The two judges moved for reconsideration. The Supreme Court granted the motion for reconsideration and rescinded the peremptory writ of prohibition, holding that the Probate Court acted within its jurisdiction and in accordance with its authority in placing M.S. for adoption with the consent of her mother. View "State ex rel. Allen County Children Services Board v. Mercer County Common Pleas Court, Probate Division" on Justia Law

The State filed a complaint against D.S. in the juvenile court, alleging that D.S., who was seventeen years old, was delinquent for approaching a couple about to enter their home, brandishing a firearm, and robbing them of their possessions. At the time of the juvenile court’s disposition, D.S. had been held for more than nine months in detention. Defendant requested confinement credit, but the juvenile court denied the request. D.S. appealed. The State conceded that the juvenile court erred in not granting D.S. credit for the time he was confined prior to disposition. On appeal, the court of appeals affirmed the juvenile court’s order. The Supreme Court reversed, holding that Ohio Rev. Code 2152.18(B) requires that predisposition confinement be credited to a juvenile. Remanded for further proceedings, including the proper calculation and award of preconfinement credit. View "In re D.S." on Justia Law

Appellant pleaded guilty to two counts of second-degree murder, among other offenses. Appellant was sentenced to two life terms of incarceration, to run consecutively. Appellant filed in the trial court in his criminal case a motion to modify his sentence, asserting that he should have been sentenced as if he had been convicted of manslaughter rather than murder. Appellant further argued that, under Ohio Rev. Code 2929.61(A), none of his sentences should have been greater than one to twenty years and that they should have been imposed to run concurrently rather than consecutively. The trial judge overruled the motion. Thereafter, Appellant filed a petition seeking a writ of mandamus based on the same argument he made in his motion to modify his sentence. The Supreme Court denied relief, holding that Appellant’s argument misinterpreted section 2929.61(A), sentencing errors are generally not remediable by extraordinary writ, and Defendant had access to an adequate remedy in the ordinary course of law. View "State ex rel. Ridenour v. O'Connell" on Justia Law