Justia Ohio Supreme Court Opinion Summaries

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

Defendant pled guilty to two counts of receiving stolen property, one a felony and the other a misdemeanor. The court of common pleas ordered Defendant to serve the felony and misdemeanor sentences consecutively. Defendant appealed, arguing that a sentencing order running a jail term for a misdemeanor consecutively to a prison sentence for a felony is contrary to Ohio Rev. Code 2929.41. The court of appeals reversed the part of the trial court’s order that imposed the two sentences consecutively and modified the sentence to run the terms of confinement concurrently. The Supreme Court affirmed, holding that a trial court may not impose consecutive sentences for felony and misdemeanor convictions under Ohio Rev. Code 2929.41(B)(1). Remanded. View "State v. Polus" on Justia Law

The Village of Piketon and Boone Coleman Construction, Inc. entered into a contract for construction of a public road. The contract contained a liquidated damages provision specifying that Boone Coleman would pay $700 to Piketon for each day after the specified completion date that the contract was not substantially completed. Boone Coleman did not complete the project until well over a year after the parties’ extended completion date. Boone Coleman sued Piketon alleging that Piketon had failed to pay $147,477 of the contract price for the construction. Piketon filed a counterclaim seeking liquidated damages. The trial court awarded Piketon $277,900 in liquidated damages. The appellate court reversed, holding that the resulting amount of liquidated damages was so unreasonable as to constitute a penalty. The Supreme Court vacated the judgment of the court of appeals, holding that the court erred in its use of a retrospective analysis to reach its conclusion and in failing to focus on the per diem nature of the liquidated damages. Remanded for consideration of the enforceability of the liquidated damages provision in light of this opinion. View "Piketon v. Boone Coleman Constr., Inc." on Justia Law

In 2006, Appellant was convicted of one count of rape and three counts of gross sexual imposition (GSI). Appellant was sentenced to life in prison for the rape conviction and four years for each of the three GSI convictions. The sentence for one of the GSI convictions was to be served concurrently with the life sentence, and the sentences for the other two GSI convictions were to be served consecutively to each other and to the life sentence. In 2015, Appellant filed this original action for a writ of habeas corpus asserting that he had served the minimum required eight years for two counts of GSI and was therefore eligible for parole. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant was not entitled to relief in habeas corpus because his maximum sentence had not expired and he had available various remedies to challenge his sentence by way of appeal and in postconviction relief and mandamus proceedings. View "State ex rel. Lockhart v. Sheldon" on Justia Law

Appellant was convicted of rape, attempted murder, kidnapping, and burglary. Appellant later filed a petition for postconviction relief, which was untimely. The trial judge denied the petition without issuing findings of fact or conclusions of law. Appellant subsequently filed this action requesting a writ of mandamus compelling the judge to issue findings of fact and conclusions of law with respect to the denial of his postconviction relief petition. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant’s petition for a writ of mandamus was properly denied where Appellant had no clear legal right to the relief he requested, the trial judge had no clear duty to provide it, and Appellant had an adequate remedy at law. View "State ex rel. Dillon v. Cottrill" on Justia Law