Justia Ohio Supreme Court Opinion Summaries

Defendant pleaded guilty to the rape and murder of his grandmother and the murder of her husband. Defendant was sentenced to death for the aggravated murders. The Supreme Court affirmed the convictions and death sentences, holding (1) the trial court did not improperly deny Defendant’s request for self-representation; (2) the trial court did not violate Defendant’s right against self-incrimination when it denied Defendant’s motion to suppress certain statements he made; (3) Defendant’s challenges to the trial court’s evidentiary rulings were unavailing; (4) Defendant’s counsel provided constitutionally effective assistance; (5) any misconduct on the part of the prosecutor was not prejudicial; (6) there were no prejudicial errors in the sentencing opinion; and (7) the imposition of the death sentences was appropriate and proportional. View "State v. Obermiller" on Justia Law

Defendant entered a no-contest plea to charges of aggravated robbery and aggravated murder with capital specifications. Defendant was sentenced to death for the murder. The Supreme Court affirmed Defendant’s convictions and death sentence, holding (1) Defendant’s constitutional challenges to Ohio’s death penalty laws were unavailing; (2) the trial court erred by denying one of seven pretrial motions Defendant filed, but in so doing, the trial court did not undermine Defendant’s right to a jury trial; (3) the trial court did not err by denying Defendant’s motion to have a copy of the prosecutor’s complete file turned over to the court for review; (4) the trial court correctly denied Defendant’s motions to suppress his confession; (5) the trial court did not err by admitting fingerprint evidence; (6) the prosecutor did not engage in impermissible misconduct; (7) Defendant received effective assistance of counsel; and (8) Defendant’s death sentence was appropriate. View "State v. Belton" on Justia Law

Daniel Stolz worked for a subcontractor on a construction project when he was injured in an accident on the job site. Prior to the accident, Messer had obtained authority from the Ohio Bureau of Workers’ Compensation to act as the self-insuring employer on the project, which gave Messer responsibility for providing workers’ compensation coverage for its own employees as well as the employees of enrolled subcontractors on the project. Stolz brought negligence claims against Messer Construction, the general contractor, and several subcontractors. A federal district court granted summary judgment to Messer as the self-insuring employer but denied summary judgment to the subcontractors, concluding that an enrolled subcontractor on a self-insured construction project is immune from claims made by its own employees but not from those made by employees of other enrolled subcontractors. The federal court then certified a question of state law to the Supreme Court. The Supreme Court answered that subcontractors enrolled in a self-insured construction project plan are immune from tort claims for workplace injuries from employees of other enrolled subcontractors on the same project. View "Stolz v. J & B Steel Erectors, Inc." on Justia Law

Seventeen-year-old Kelli Baker was driving on a county road when one of her tires slipped off the right side of the road. The car hit a tree and caught on fire, killing Baker. Baker’s estate and parents filed a wrongful-death lawsuit against Wayne County and its employees. The trial court granted summary judgment for Defendants. The court of appeals reversed, concluding that the edge drop that existed on the county road at the time of Baker’s accident could give rise to Defendants’ liability under Ohio Rev. Code 2744.02(B)(3) for negligently failing to keep “public roads” in repair. The Supreme Court reversed, holding that an edge drop at the limit of a paved roadway is not part of “public road” as defined in Ohio Rev. Code 2744.01(H), and therefore, Plaintiffs’ claims were barred by sovereign immunity. View "Baker v. Wayne County" on Justia Law

Plaintiff was at Indian Lake State Park, which is open to the public without an admission charge, when he was seriously injured by a rock thrown by an Ohio Department of Natural Resources (ODNR) boom mower that struck him in the eye. Plaintiff sued ODNR for negligence. The court of claims granted summary judgment for ODNR, concluding that because Plaintiff was a recreational user, ODNR had no duty to keep the park safe for Plaintiff’s entry or use. The court of appeals reversed, concluding that because Plaintiff claimed he was injured by the negligence of a park employee and not by a defect in the premises, the recreational user statute did not apply. The Supreme Court affirmed, holding (1) the evidence in this case showed that Plaintiff’s injuries resulted from the alleged negligent operation of a boom mower, not from the condition of the premises; and (2) therefore, the recreational user statute does not preclude liability for Plaintiff’s negligence claim if Plaintiff can establish that negligence. View "Combs v. Ohio Dep’t of Natural Res., Div. of Parks & Recreation" on Justia Law

Appellant was convicted of murder. While incarcerated, Appellant filed a motion to vacate his conviction and sentence. When the trial court took no action on his motion, Appellant filed a petition in procedendo in the court of appeals. Thereafter, the county court of common pleas judge denied Appellant’s trial court motion. The judge then filed a motion to dismiss in the procedendo action. The motion was converted to one for summary judgment, and the writ was denied. The Supreme Court affirmed, holding that Appellant’s action in procedendo was moot, as the trial judge ruled on Appellant’s motion to vacate. View "State ex rel. Morgan v. Fais" on Justia Law

John Nye was convicted of a violation of a city ordinance. Judge Lisa Coates, the trial court judge in the case, adopted and approved the magistrate’s decision. However, there was no order in the record that set forth a finding of guilt with the imposition of a sentence. Nye appealed. While the appeal was questioned for want of a final, appealable order, it was ultimately dismissed for failure to prosecute. Thereafter, Nye filed an action in precedendo against Judge Coates. The court of appeals granted the writ, concluding that, in a criminal matter, a trial court must enter judgment separately on all claims and may not simply refer to the magistrate’s decision. Judge Coates subsequently filed a new order that complied with Ohio R. Crim. P. 32(C). Nye appealed, asserting, as he did in the court below, a right to a magistrate’s decision that complies with the form requirements of Ohio R. Crim. P. 19(D)(3)(a)(iii) and a right to findings of fact and conclusions of law from the magistrate. The Supreme Court dismissed the appeal, holding that Nye had an adequate remedy in the ordinary course of law, precluding a writ. View "State ex rel. Nye v. Coates" on Justia Law

Christian Voice of Central Ohio operated a radio station from offices located in New Albany. In 1991, the tax commissioner granted an exemption for the property on the grounds that it was being used for church purposes. In 2007, following the relocation of Christian Voice’s offices to Gahanna, a complaint was filed challenging the continued exemption of Christian Voice’s New Albany property. The tax commissioner denied the complaint. In 2008, Christian Voice applied for the same exemption for its Gahanna property. The tax commissioner denied the exemption, finding no evidence that people assembled to worship together on the subject property. The Board of Tax Appeals (BTA) affirmed. The Supreme Court reversed, holding that the BTA should have allowed the exemption under Ohio Rev. Code 5709.07(A)(2) because the primary use of the property was for public worship. View "Christian Voice of Cent. Ohio v. Testa" on Justia Law

Appellant was found guilty of disorderly conduct. In appealing that judgment pro se, Appellant filed a complaint for a writ of mandamus under the same case number as the appeal. Appellant also filed a motion for a stay of the appeal proceedings pending resolution of the mandamus action. The court of appeals struck the complaint on the grounds that a mandamus action is not properly filed as a pleading in a pending appeal. Appellant appealed the court of appeals’ entry striking the mandamus complaint as well as subsequent entries issued by the court of appeals. The Supreme Court dismissed the appeal in part and affirmed in part, holding (1) as to four of the court of appeals’ entries, Appellant’s appeal is dismissed because his notice of appeal is untimely; and (2) to the extent that later entries pertain to Appellant’s mandamus action, the court of appeals is affirmed. View "State v. Henry" on Justia Law

Chester Township and its trustees (collectively, Relators) sought to prohibit Judge Timothy Grendell (Respondent) from issuing or enforcing rulings against them in the case that created the Chester Township Park District, arguing that the probate court lacked subject matter jurisdiction to issue orders attempting to correct activities by the park-district commissioners and the township trustees that frustrated the purpose of the original probate court order creating the park district. The probate court, in turn, asserted that it had continuing subject matter jurisdiction over the case creating the park district. The Supreme Court denied the writ, holding that the township trustees failed to show that the probate court patently and unambiguously lacked jurisdiction to issue the orders at issue. View "State ex rel. Chester Twp. v. Grendell" on Justia Law