Justia Ohio Supreme Court Opinion Summaries

Defendant was entered a guilty plea to charges of murder, domestic violence, and aggravated murder with capital specifications for the murders of his former girlfriend, their two-year-old son, and his girlfriend’s nine-year-old daughter. A three-judge panel unanimously sentenced Defendant to death of the aggravated murders of the two children and to fifteen years to life for his girlfriend’s murder. The Supreme Court affirmed Defendant’s convictions and sentence of death, holding (1) the panel did not err by failing sua sponte to order Defendant to undergo a competency evaluation; (2) the evidence presented during the plea hearing was sufficient to convict Defendant of the escaping detection specification attached to an aggravated murder, and defendant’s conviction of that specification was not against the manifest weight of the evidence; (3) defense counsel provided constitutionally effective assistance during the plea and mitigation hearings; (4) Defendant was not denied due process of law and a fair trial when the panel admitted and considered graphic photographs during the plea and mitigation hearings; and (5) Defendant’s death sentence was appropriate and proportionate. View "State v. Montgomery" on Justia Law

In 2013, Shawn Valentine was elected trustee of Spencer Township in Lucas County. In 2015, Valentine, who serves in the Ohio Army National Guard, told the two other trustees of his military deployment but that he did not intend to resign his position as trustee. The two trustees subsequently voted to declare Valentine’s office vacant and then appointed one of the trustees, D. Hilarion Smith, to take Valentine’s trustee position. Relator, the Lucas County prosecuting attorney, sought a peremptory writ of quo warranto seeking to remove Smith from the office of township trustee and a declaration that Valentine was the rightful holder of that position. The Supreme Court granted the writ, holding (1) under the plain language of Ohio Rev. Code 503.241, Smith usurped the title and authority of Valentine’s office of township trustee; and (2) the board of township trustees violated the Open Meetings Act when it unlawfully appointed Smith to Valentine’s trustee position. View "State ex rel. Bates v. Smith" on Justia Law

On December 22, 2015, Respondents submitted part-petitions in support of an initiative to enact the "Ohio Drug Price Relief Act." On February 29, 2016, the Ohio Manufacturers’ Association and others commenced this original protest action identifying three alleged defects in the part-petitions that they claimed should cause the part-petitions to be discounted in their entirety. The Supreme Court sustained the challenge in part, holding that 10,303 signatures, including the signatures on all part-petitions circulated by two petition circulators in particular, were erroneously validated because either the circulators submitted false information in their circulator statements or the part-petitions had overcounts. View "Ohio Manufacturers' Ass’n v. Ohioans for Drug Price Relief Act" on Justia Law

Defendant, a police officer, was charged with one count of unlawful sexual conduct with a minor and one count of sexual battery. A bench trial resulted in Defendant’s conviction for sexual battery under Ohio Rev. Code 2907.03(A)(13), which makes peace officers strictly liable for sexual conduct with anyone under the age of eighteen when the offender is more than two years older. The appellate court reversed, concluding that section 2907.03(A)(13) violated equal protection and was facially unconstitutional. The Supreme Court affirmed, holding that the statute is an arbitrarily disparate treatment of peace officers that violates equal protection principles under the state and federal constitutions. View "State v. Mole" on Justia Law

Appellant filed two legal actions. Appellant filed a complaint in federal court alleging violations of his due process and equal protection rights. The federal district court dismissed the complaint, and Appellant appealed. Appellant also filed this original action seeking a writ of mandamus to compel an employee of JPMorgan Chase Bank to pay him a certain amount of money. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that Appellant’s claims were barred by res judicata, Appellant had an adequate remedy in the ordinary course of law, and Appellant failed to identify a clear legal right to the relief he sought. View "State ex rel. McQueen v. Weibling-Holliday" on Justia Law

Appellant, an inmate, filed a petition for a writ of habeas corpus arguing that his aggregate sentence had expired and that he was entitled to immediate release. Appellee, Warden Brigham Sloan, moved to dismiss the petition, arguing, among other things, that Appellant failed to state a claim upon which relief could be granted because his sentence did not expire until 2039. The court of appeals granted the motion to dismiss. The Supreme Court affirmed, holding that the habeas petition was properly dismissed because Appellant failed to attach all his required commitment papers to the petition. View "State ex rel. Jackson v. Sloan" on Justia Law

Appellee was charged with rape and kidnapping. Appellee filed a motion to dismiss the indictment based on unconstitutional preindictment delay. The court of common pleas dismissed the charges, concluding that the State’s indictment of Appellee one day before the expiration of the applicable twenty-year statute of limitations prejudiced Appellee. The court of appeals affirmed, concluding that Appellee suffered actual prejudice as a result of the nearly twenty-year delay between the alleged offenses and the indictment. The Supreme Court reversed, holding that the court of appeals applied an incorrect standard in its analysis of Appellee’s preindictment-delay claim. Remanded. View "State v. Jones" on Justia Law

At issue in this case was property owned by Innkeeper Ministries, Inc. that contained two large residential buildings and various recreational amenities. Innkeeper’s mission was to invite religious leaders to stay at the property at no charge and to enjoy the amenities and free meals as a type of spiritual retreat. Innkeeper filed an exemption application in 2008 seeking an exemption for, inter alia, charitable use. The tax commissioner denied exemption, stating, as for charitable use, that the activity at issue did not meet the charity standard. The Board of Tax Appeals (BTA) reversed. The Supreme Court reversed, holding that, given the residential use of the property by a caretaker couple, the BTA erred by failing to require proof of the primacy of charitable hospitality. View "Innkeeper Ministries, Inc. v. Testa" on Justia Law

Plaintiff sustained injuries as a result of a motorcycle accident involving a Cleveland Electric Illuminating Company (CEI) utility pole. Plaintiff and his wife sued CEI, FirstEnergy Service Company (First Energy), and their parent company (collectively, Defendants), asserting, inter alia, claims for negligence and qualified nuisance. The jury returned a verdict for Plaintiffs on their qualified nuisance and loss of consortium claims but returned a verdict for CEI and FirstEnergy on the negligence claim. Defendants appealed, arguing that Turner v. Ohio Bell Tel. Co. provided an absolute bar to liability. The Supreme Court reversed, holding that, as a matter of law, CEI and FirstEnergy could not be held liable under any theory of liability asserted by Plaintiffs. View "Link v. FirstEnergy Corp." on Justia Law

Manuel Perez was injured while working in the construction industry and was awarded temporary-total-disability compensation. Prior to his injury, Perez owned and was operating an auto-repair business. Years later, the Industrial Commission of Ohio determined that Perez was overpaid temporary-total-disability compensation for more than four years and that he committed fraud in applying for it. The court of appeals affirmed the Commission’s finding of an overpayment and dismissed the fraud finding for insufficient evidence. The Supreme Court affirmed in part and reversed in part, holding that the Commission did not abuse its discretion (1) in finding that Perez had been overpaid compensation while operating his auto-repair business; and (2) when it concluded that the evidence supported a finding of fraud. View "State ex rel. Perez v. Indus. Comm'n" on Justia Law