Justia Ohio Supreme Court Opinion Summaries

Relators, the Ohio Manufacturers’ Association and others, filed this original petition challenging the petition signatures submitted in support of the Ohio Drug Price Relief Act (Act). The committee responsible for the Act petition (committee) filed a motion for judgment on the pleadings, asserting that a challenge to the specific part-petitions at issue did not fall within the scope of the Court’s original jurisdiction. The Supreme Court rejected the committee’s jurisdictional arguments and denied the committee’s alternative arguments for partial judgment on the pleadings, holding (1) the Court has original jurisdiction over this petition challenge pursuant to Ohio Const. art. II, 1g; and (2) the committee’s alternative arguments were unavailing. View "Ohio Manufacturers' Ass’n v. Ohioans for Drug Price Relief Act" on Justia Law

Appellant made a public-records request of the City of Avon Lake for invoices from a law firm for services rendered in connection with litigation between Appellant and the City. When the City provided redacted invoices Appellant filed a petition for a writ of mandamus in the court of appeals requesting an order compelling the City to provide unredacted invoices. The court of appeals granted a writ of mandamus compelling the City to provide Appellant with copies of the relevant billings statements with an unredacted “professional fee summary” and otherwise denied Appellant’s petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate that he was entitled to extraordinary relief in mandamus. View "State ex rel. Pietrangelo v. City of Avon Lake" on Justia Law

In 2004, a jury found Appellant guilty of aggravated murder. In 2015, Appellant filed a motion to correct the judgment entry. The county court of common pleas judge denied the motion. Appellant subsequently filed an action in mandamus in the court of appeals. The judge filed a motion to dismiss, asserting that Appellant failed to meet the requirements for a late petition for postconviction relief and that his motion to correct the judgment entry was barred by res judicata. The court of appeals granted the motion to dismiss. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of law. View "State ex rel. Bradford v. Dinkelacker" on Justia Law

Plaintiff filed an ex parte action for replevin in the county court of common pleas. Plaintiff subsequently voluntarily dismissed the case and filed a complaint for a writ of prohibition in the court of appeals to prevent the court of common pleas judge and magistrate from taking any further action in the dismissed replevin case. The court of appeals issued a short journal entry stating that “this procedendo action is moot” and dismissed the action. The Supreme Court reversed, holding that the court of appeals erred in dismissing the case as a moot action in procedendo. Remanded with instructions that the court of appeals consider the arguments of the parties and conduct an analysis to determine whether a writ of prohibition should be issued. View "State ex rel. Dunn v. Franklin County Court of Common Pleas" on Justia Law

Plaintiffs sued World Harvest Church (WHC) for claims arising from an incident involving Plaintiffs’ two-year-old son, who attended WHC’s daycare. Plaintiffs alleged that WHC’s employee had beaten their son with a knife. Final judgment was entered in favor of Plaintiffs in the amount of $2.87 million. The court of appeals affirmed. WHC subsequently filed suit against Grange Mutual Casualty Company, which insured WHC under a commercial liability insurance policy and an umbrella policy and had defended the matter but reserved its right to deny coverage. Plaintiffs alleged that Grange improperly refused to indemnify it for any portion of the judgment awarded to Plaintiffs. The trial court entered judgment in favor of WHC, finding that Grange was obligated to indemnify WHC in the amount of $1.47 million but that Grange was not responsible to indemnify WHC for the punitive damages awarded to Plaintiffs. The Supreme Court reversed, holding (1) the abuse or molestation exclusion in the commercial liability insurance policy barred coverage for an award of damages based on WHC’s vicarious liability for intentional infliction of emotional distress arising from WHC’s employee’s abuse of Plaintiff’s son while in WHC’s care and custody; and (2) the policy did not provide coverage for an award of attorney fees and postjudgment interest. View "World Harvest Church v. Grange Mut. Cas. Ins. Co." on Justia Law

Marcus Pryor applied to the Ohio Department of Job and Family Services (ODJFS) for unemployment compensation. The director of ODJFS concluded that Pryor was ineligible for benefits. A hearing officer with the Unemployment Compensation Review Commission affirmed. The Commission denied Pryor’s request to review the hearing officer’s findings. Pryor filed an appeal in the common pleas court naming the director of ODJFS as the appellee but failing to name the Army, Pryor’s former employer, as a party to his appeal. The common pleas court dismissed the appeal, finding that because Pryor failed to name the Army was an interested party, his notice of appeal did not comply with Ohio Rev. Code 4141.282(D), thus depriving the court of subject-matter jurisdiction. The court of appeals reversed the common pleas court’s dismissal of Pryor’s appeal and reinstated Pryor’s administrative appeal in the common pleas court, ruling that Pryor’s failure to name the Army was not a jurisdictional defect. The Supreme Court reversed, holding (1) the naming of interested parties is not a jurisdictional requirement under section 4141.282; but (2) the Commission failed to comply with the procedural requirements in section 4141.282(D), and therefore, Pryor’s time to appeal the Commission’s decision never started to run. Remanded. View "Pryor v. Dir., Ohio Dep’t of Job & Family Servs." on Justia Law

Defendant pleaded guilty to attempted abduction and was sentenced to a term of community control. The trial court subsequently found that Defendant had violated the terms of his community control and extended the term of community control. Thereafter, the trial court issued an order declaring that the county probation department, rather than the county prosecuting attorney, represents the State in all community control violation proceedings and that the prosecutor would not be notified of any future hearings. The trial court then conducted a community control violation hearing in Defendant’s case. An assistant prosecuting attorney asserted the right to be present and heard. The trial court denied the prosecuting attorney an opportunity to speak. The court found that Defendant had violated the conditions of community control and imposed a fourteen-day jail sentence. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court erroneously vested probation officers, rather than prosecutors, with the authority to represent the interests of the State, and therefore, as the State’s legal representative, the prosecuting attorney is entitled to proper notice and an opportunity to appear and be heard at community control violation proceedings. View "State v. Heinz" on Justia Law

Several school districts filed complaints seeking reimbursement for retroactive reductions in school foundation funding. The State Board of Education of Ohio (the department) moved for judgment on the pleadings, arguing that it was insulated from liability. The trial court held that the General Assembly did not have the constitutional authority to adjust local school funding retrospectively. The Court of Appeals affirmed. The Supreme Court reversed, holding that the General Assembly had constitutional authority to retroactively reduce the amount of state funding allocated to local school districts and to immunize the department against the school districts’ legal claims. Remanded. View "Toledo City Sch. Dist. Bd. of Educ. v. State Bd. of Educ." on Justia Law

Appellant, a nonresident taxpayer, filed a refund claim for an unpaid 2004 tax liability assessment. Appellant contested Ohio Rev. Code 5747.212’s imposition of income tax on a portion of the capital gain that he realized in 2004 when he sold his ownership interest in a limited liability company. The tax commissioner denied the refund claim. The Board of Tax Appeals (BTA) affirmed. Appellant appealed, arguing that applying section 5747.212 to him was unconstitutional and that he should be permitted to allocate the gain entirely outside Ohio. At issue before the Supreme Court was whether Ohio may levy income tax on Appellant’s capital gain as if it were income from the business itself. The Supreme Court reversed the decision of the BTA, holding that section 5747.212, as applied to Appellant, violates the Due Process Clause of the Fourteenth Amendment. Remanded to the tax commissioner to grant Appellant a refund. View "Corrigan v. Testa" on Justia Law

Appellee applied to the court of common pleas to seal his twenty-four-year-old third-degree-felony conviction for receiving stolen property. The State objected to the application, arguing that Appellee’s fourth-degree-misdemeanor conviction under Ohio Rev. Code 4503.11(A) for failing to register a motor vehicle must be counted as a conviction when determining eligibility. The trial court ordered sealed Appellee’s felony conviction for receiving stolen property. The Court of Appeals affirmed. The Supreme Court reversed, holding (1) a violation of section 4503.11 concerning failure to register a motor vehicle must be counted as an offense when determining eligible offender status for record-sealing purposes under Ohio Rev. Code 2953.31; and (2) the Court of Appeals incorrectly held that Appellee was an eligible offender for record-sealing purposes. Remanded. View "State v. J.M." on Justia Law