Justia Ohio Supreme Court Opinion Summaries

In 2003, Appellant was convicted of two counts of rape. The sentencing entry stated that Appellant “shall be subject to post release control of up to three years.” The trial court later journalized a nunc pro tunc order correcting the 2003 order by stating that Appellant “shall be subject to post release control of up to five years.” After completing his term of incarceration, Appellant filed a motion to terminate postrelease control. The court of common pleas found that the motion was actually a petition for postconviction relief and dismissed it as untimely. Appellant filed filed an action in mandamus and/or prohibition requesting a writ compelling the trial court to issue a valid final judgment in the underlying case. The court of appeals dismissed the petition, concluding that the trial court lost jurisdiction to take action in the criminal case where Appellant had served the maximum prison term. The Supreme Court affirmed on the basis that Appellant had an alternate remedy in the ordinary course of law by way of appealing the trial court’s dismissal of his motion to terminate his postrelease control. View "State ex rel. Rudert v. Collier" on Justia Law

Sarunas Abraitis, the former executor of his mother’s estate, applied to admit his mother’s will to probate. The will provided that if Abraitis’s father predeceased his mother, her entire estate would be divided equally between Abraitis and his brother, Vytautas. The matter was assigned to Judge Laura Gallagher. While the estate was being administered, Vytautas died. Abraitis subsequently filed an application to probate a different, later will that his mother executed and that bequeathed to him the entire estate. Vytautas’s former wife, Vivian, filed a complaint to contest the later will. The action was also assigned to Judge Gallagher. Abraitis filed two actions in prohibition alleging that Judge Gallagher lacked jurisdiction. As grounds for the writ, Abraitis referred to collateral proceedings regarding his mother’s guardianship and federal and state tax proceedings, arguing that because none of the parties objected or moved to intervene in the tax cases, the probate court was precluded from hearing any matter concerning the estate. The court of appeals dismissed Abraitis’s complaints in prohibition. The Supreme Court affirmed, holding that Abraitis had an adequate remedy in the ordinary course of the law and that Judge Gallagher did not patently and unambiguously lack jurisdiction over the probate court action. View "State ex rel. Abraitis v. Gallagher" on Justia Law

In 1991, Larry Dawson was convicted of aggravated murder and other crimes. In 2012, Dawson filed a motion for an oral hearing to correct a “void” sentence on the alleged ground that the entry did not address all the charges. Judge Lynne Callahan denied the motion. Dawson appealed. The appellate court concluded that the original sentencing entry was a final, appealable order and that Dawson’s sentencing entry disposed of all charges against him. In 2014, Dawson moved the court to issue a valid judgment. Judge Callahan denied the motion. Dawson then petitioned the Court of Appeals for a writ of mandamus and/or procedendo ordering Judge Callahan and the Summit County Court of Common Pleas (collectively, Respondents) to resentence him and issue a final judgment of conviction. The Court of Appeals concluded that Dawson was not entitled to either writ. The Supreme Court affirmed, holding that because Dawson could have raised the issues in his direct appeal that he asserts now, and because the same issue had already been addressed in the appeal of Dawson’s motion for a new sentence, the case is res judicata. View "State ex rel. Dawson v. Summit County Court of Common Pleas" on Justia Law

After a bench trial, Defendant was found guilty of domestic violence, a misdemeanor in the first-degree. During trial, the victim asserted the privilege against self-incrimination at least eight times in response to questions posed to him about Defendant’s assault. Defendant appealed, raising four claims of error. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by the trial court’s inquiry into the victim’s claim of privilege nor by the trial court’s instruction to the victim to read his prior statement during his examination; (2) Defendant failed to establish that an impermissible judicial bias deprived him of a fair trial; and (3) assuming the trial court erred in allowing the victim to read his prior statement at trial, the error was harmless beyond a reasonable doubt. View "State v. Arnold" on Justia Law

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