Justia Ohio Supreme Court Opinion Summaries

James Smith was indicted on one count of aggravated burglary and one count of rape. Smith was subsequently reindicted on the same two counts, in addition to one count of cocaine possession. Thereafter, the trial court dismissed the earlier indictment. Defendant was found guilty of aggravated burglary and rape. Smith later filed a motion for a new trial, arguing that he received ineffective assistance of counsel because he was convicted on a dismissed indictment. The trial court denied the motion. Smith then filed this original action in the Court of Appeals seeking a writ of prohibition against Judge Michael Hall and his successor, Judge Dennis Adkins, asserting that Judge Hall lacked jurisdiction in his case because his conviction arose from an indictment that had been dismissed prior to trial. The Court of Appeals dismissed Smith’s complaint for a writ of prohibition, determining that a writ of prohibition was not appropriate. The Supreme Court affirmed, holding that Appellant had adequate remedies in the ordinary course of law. View "State ex rel. Smith v. Hall" on Justia Law

After his alleged biological son, B.V., was placed for adoption, Steven Walton filed a paternity case in juvenile court seeking to establish his father-child relationship and parental rights and responsibilities regarding B.V. Walton and B.V.’s biological mother later submitted an acknowledgment-of-paternity affidavit to the Central Paternity Registry. Walton then voluntarily dismissed his paternity action and moved the probate court for summary judgment on the adoption, relying on the enforceability of the acknowledgment of paternity. Thereafter, Adoption Connection, the adoption agency with legal custody of B.V., filed a complaint in the juvenile court asking the juvenile court to declare the paternity acknowledgment void. The case was assigned the case number for the paternity case that Walton had voluntarily dismissed. Walton filed this original action in prohibition to stop Respondents - the juvenile court judge and magistrate - from exercising jurisdiction in Adoption Connection’s case. The Supreme Court granted the writ, holding that the juvenile lacked jurisdiction because Walton’s paternity case had been voluntarily dismissed. View "State ex rel. Walton v. Williams" on Justia Law

Appellant was convicted of aggravated murder with two felony-murder specifications. Appellant was sentenced to death. After Appellant exhausted his postconviction and federal remedies, the Supreme Court ordered the execution to proceed on September 15, 2009. During the scheduled execution, attempts to insert an IV catheter were unsuccessful. Appellant was injected eighteen times during the botched attempt. Appellant pursued multiple avenues challenging any further attempt by the State to execute him. This appeal arose from Appellant’s successive petition for postconviction relief, in which he asserted that any future attempt to execute him would violate the Cruel and Unusual Punishments and Double Jeopardy Clauses of the United States and Ohio Constitutions. The trial court denied Appellant’s petition without an evidentiary hearing. The Court of Appeals affirmed. The Supreme Court affirmed, holding that the State was not constitutionally barred from carrying out Appellant’s execution. View "State v. Broom" on Justia Law

The juvenile court adjudicated Appellant, a juvenile, delinquent on sex offenses. At disposition, the juvenile court did not record a finding regarding Appellant’s age at the time the offenses were committed. Upon Appellant’s release from the Ohio Department of Youth Services, the court scheduled a sex-offender-classification hearing. Appellant opposed his classification as a juvenile-sex-offender registrant, arguing that he was ineligible for classification because he was under the age of fourteen when the offenses were committed and because classification would violate the constitutional prohibition against double jeopardy. After a hearing, the juvenile court found (1) Appellant had committed at least one offense when he was fourteen years of age, and (2) Appellant should be designated a juvenile offender registrant and classified as a Tier II offender. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a determination of a juvenile sex offender’s age at the time of the offense can be made at any time prior to or during the classification hearing; and (2) the imposition of classification upon release from a secure facility and for a time period beyond the juvenile offender’s attainment of age eighteen or twenty-one does not violate the offender’s due process rights or the constitutional prohibition against double jeopardy. View "In re D.S." on Justia Law

Appellant filed a public-records request under the Ohio Public Records Act for the personnel records of six employees of the West Licking Joint Fire District. Less than three business days later, Appellant filed a complaint for a writ of mandamus in the court of appeals. The district’s counsel completed the review of the requested records the same day, and the district sent the documents to Appellant that afternoon. The district did not become aware of Appellant’s complaint until the next day. The court of appeals concluded that the records were produced in a reasonable amount of time and that Appellant had engaged in frivolous conduct. The Supreme Court affirmed in part but found that the court of appeals abused its discretion when it failed to hold a show-cause hearing before finding that Appellant had engaged in frivolous conduct. On remand, the court of appeals held the required hearing and found that Appellant engaged in frivolous conduct, thus awarding attorney fees. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion in finding that the continuation of unnecessary discovery after the requested records were provided was frivolous conduct. View "State ex rel. Davis v. Metzger" on Justia Law

Plaintiff, individually and on behalf of her daughter, filed a civil suit against Defendant for assault, false imprisonment, emotional distress, and loss of consortium. Plaintiff requested compensatory and punitive damages. After Defendant failed to respond to the complaint, the trial court entered a default judgment against her. Before the damages hearing, Defendant died. The administrator of Defendant’s estate was substituted as a party. After a hearing, the trial court awarded compensatory damages to Plaintiff’s two daughters and concluded that punitive damages could not be properly awarded against the estate of a deceased tortfeasor. The Court of Appeals reversed, concluding that Ohio law permits an award of punitive damages against a deceased tortfeasor. The Supreme Court affirmed, holding that a punitive damages award is available in the limited circumstances presented in this case. Remanded to the trial court for a hearing on punitive damages and attorney fees. View "Whetstone v. Binner" on Justia Law

After a jury trial, Defendant was found guilty of one count of manufacturing methamphetamine in the vicinity of a juvenile, a felony. The trial court sentenced Defendant to ten years’ imprisonment. The maximum possible term was eleven years. Defendant appealed, arguing that the trial court abused its discretion by imposing a near-maximum prison term. The Court of Appeals refused to apply an abuse-of-discretion standard to felony-sentencing appeals and affirmed Defendant’s sentence. The Supreme Court affirmed, holding (1) pursuant to Ohio Rev. Code 2953.08(G)(2), an appellate court may vacate or modify a felony sentence on appeal only if it finds by clear and convincing evidence that the record did not support the sentencing court’s decision or that the sentence was otherwise contrary to law; and (2) the Court of Appeals applied the correct standard of review in this case. View "State v. Marcum" on Justia Law

At issue in this case was the value for tax year 2012 of four residential properties used as rental properties. The Franklin County Board of Revision (BOR) ordered reductions based on unspecified area sale prices and rents. The Board of Tax Appeals (BTA) retained the BOR’s reduced valuations of the property. The Columbus City Schools Board of Education (BOE) appealed, asking that the Supreme Court reverse the BTA’s decision and reinstate the original valuations found by the county auditor. The Supreme Court affirmed based on the authority of Columbus City Schools Bd. of Educ. v. Franklin County Bd. of Revision, in which the Court confronted similar claims in an appeal by the BOE and rejected the claims because the BOE had not raised and preserved them before the BTA. View "Oak View Props., LLC v. Franklin County Bd. of Revision" on Justia Law

Buckeye Hospitality, Inc, the owner of a Comfort Inn hotel property located in Franklin County, filed a complaint seeking a reduction of the value assigned to its property. The Columbus City Schools Board of Education filed a countercomplaint seeking retention of the auditor’s valuation. The Franklin County Board of Revision (BOR) adopted the lower value set forth by Buckeye’s appraiser, with an adjustment. The Board of Tax Appeals (BTA) found that the valuation analysis of Buckeye’s appraiser was supported by the evidence and adopted the BOR’s approach. The Supreme Court affirmed the decision of the BTA, holding that the record contained sufficient evidence to support the decision of the BOR and the BTA. View "Columbus City Schs. Bd. of Educ. v. Franklin County Bd. of Revision" on Justia Law

Veolia Water North American Operating Services, Inc., the private owner and operator of a waste-water-treatment plant that serves both communities and certain manufacturers, sought exemption of real-estate improvements and all the personal property at the plant. The basis for its exemption claim was the treatment of industrial waste water generated by its manufacturing customers. The tax commissioner granted the exempt-facility certificate for a percentage of the personal property that reflected the amount of inflow that was industrial waste water but did not include the amount of residential waste water generated by the communities. The Board of Tax Appeals (BTA) affirmed. The Supreme Court affirmed, holding (1) the BTA’s conclusion that certain property was not entitled to the partial exemption was both reasonable and lawful; and (2) the tax commissioner did not violate its duty to give some of Veolia’s supplemental documentation to the Ohio Environmental Protection Agency. View "Veolia Water N. Am. Operating Servs., Inc. v. Testa" on Justia Law