Justia Ohio Supreme Court Opinion Summaries

The case involves East Ohio Gas Company, doing business as Dominion Energy Ohio ("Dominion"), and J. William Vigrass, individually and as executor of Virginia Vigrass’s estate. Dominion had requested access to Virginia's residence to inspect the gas meter located inside. However, due to Virginia's immunocompromised state and susceptibility to COVID-19, she denied Dominion access. Despite her account being paid in full, Dominion disconnected its natural-gas service to Virginia’s residence in January 2022. The disconnection resulted in freezing temperatures inside the residence, causing the water pipes to burst and damage the property. Virginia was later found dead in her residence.In the Cuyahoga County Court of Common Pleas, Vigrass sued Dominion on claims relating to the shutoff of its natural-gas service to Virginia’s residence. Dominion moved to dismiss the complaint for lack of subject-matter jurisdiction, arguing that the Public Utilities Commission of Ohio had exclusive jurisdiction over the claims as they related to a service issue. However, Judge Peter J. Corrigan denied Dominion’s motion, reasoning that he had jurisdiction over the complaint because Vigrass had asserted common-law claims.Dominion then filed an original action in prohibition in the Supreme Court of Ohio, asserting that Judge Corrigan patently and unambiguously lacks jurisdiction over Vigrass’s action. Dominion sought an order to prevent Judge Corrigan from exercising jurisdiction and to vacate the orders he has issued in the underlying case.The Supreme Court of Ohio granted the writ of prohibition, ordering Judge Corrigan to cease exercising jurisdiction over the underlying case and directing him to vacate the orders that he had previously issued in the case. The court concluded that both parts of the test set forth in Allstate Ins. Co. v. Cleveland Elec. Illum. Co. were met, indicating that the Public Utilities Commission of Ohio had exclusive jurisdiction over the case. The court also granted in part and denied in part Dominion's motion to strike certain parts of Vigrass's brief. View "State ex rel. E. Ohio Gas Co. v. Corrigan" on Justia Law

This case involves a dispute over a lease agreement between Tera, L.L.C., and Rice Drilling D, L.L.C., and Gulfport Energy Corporation. The lease granted Rice Drilling and Gulfport Energy certain mineral rights in the geological formations known as the Marcellus Shale and the Utica Shale beneath Tera’s land. The dispute arose when Tera claimed that the defendants had intentionally drilled six wells into the Point Pleasant formation, which Tera argued was not included in the lease agreement.The trial court awarded summary judgment to Tera, concluding that the lease agreement clearly limited the rights granted to the defendants to the Marcellus and Utica formations and reserved rights to all other formations. The court also found that the defendants had trespassed in bad faith, and a jury awarded Tera over $40 million in damages.The Court of Appeals for Belmont County affirmed the trial court's decision. The court concluded that the lease language was unambiguous and that the phrase "Utica Shale" had a technical stratigraphic meaning that did not include the Point Pleasant formation.The Supreme Court of Ohio reversed the lower courts' decisions. The court found that the lease agreement was ambiguous because it did not clearly establish whether the Point Pleasant was or was not to be considered part of the Utica Shale. The court concluded that resolving the meaning of ambiguous terms in a contract is a matter of factual determination for the fact-finder. Therefore, the court remanded the case to the trial court for further proceedings. View "Tera, L.L.C. v. Rice Drilling D, L.L.C." on Justia Law

Andre M. Yeager, an inmate at the Richland Correctional Institution, represented himself in a trial where he was found guilty of grand theft, breaking and entering, and vandalism. He was sentenced to an aggregate prison term of 39 months. Yeager appealed his convictions to the Eleventh District, arguing that the trial court erred by allowing him to represent himself. The Eleventh District affirmed the trial court’s judgment of conviction.Yeager then filed an action in the Eleventh District, seeking a writ of prohibition to prevent the trial court from enforcing his convictions and a writ of mandamus directing the trial court to vacate his convictions. He claimed that his case was improperly assigned to the trial-court judge, the trial court violated his right to counsel, and the prosecution withheld exculpatory evidence. The Eleventh District dismissed Yeager’s complaint for failure to state a claim upon which relief can be granted.The Supreme Court of Ohio affirmed the Eleventh District Court of Appeals’ judgment. The court found that Yeager had an adequate remedy in the ordinary course of the law to raise his claims, as he had already exercised that remedy by filing a direct appeal from the trial court’s judgment of conviction. The court also found that the trial court did not patently and unambiguously lack jurisdiction. Therefore, Yeager was not entitled to a writ of prohibition precluding the trial court from enforcing his convictions or a writ of mandamus vacating his convictions. View "State ex rel. Yeager v. Lake Cty. Court of Common Pleas" on Justia Law

The case revolves around Alphonso Mobley Jr., who filed a writ of mandamus against Ohio Secretary of State Frank LaRose, seeking a certified copy of a document in response to a public-records request. Mobley also sought statutory damages and court costs under R.C. 149.43(C). The document in question was the "Certified Bond of Director of Ohio Department of Rehabilitations and Corrections for year 2021-2022." Mobley had initially received an uncertified copy of the bond, and upon his second request, he enclosed a check for $5 for a certified copy. However, he alleged that the secretary had not responded to his request for a certified copy, leading him to file this action.The secretary's office sent Mobley a certified copy of the bond six business days after he filed the action. The secretary denied liability under the Ohio Public Records Act, R.C. 149.43 et seq., and stated that he had provided the requested record. The Supreme Court of Ohio granted an alternative writ and set a schedule for the parties’ submission of evidence and merit briefs.The Supreme Court of Ohio ruled that the mandamus claim was moot as the secretary had provided Mobley with a certified copy of the record he had requested. Mobley argued that the record was incomplete, but the court found no merit in his argument. The court also denied Mobley's request for statutory damages, stating that the failure to provide a certified copy within a reasonable time is not a failure to comply with an obligation under R.C. 149.43(B). The court also denied Mobley's claim for court costs, as he had filed an affidavit of indigency and therefore had no obligation to pay costs. View "State ex rel. Mobley v. LaRose" on Justia Law

The case revolves around James E. Mitchell, an inmate serving a 160-year prison sentence for a 1994 conviction in Summit County, which is to be served consecutively to a 3- to 15-year prison sentence imposed for a June 1994 conviction in Portage County. Mitchell filed a petition for a writ of habeas corpus against Warden George A. Fredrick and the Ohio Adult Parole Board, arguing that the Portage County trial court lacked jurisdiction when it sentenced him on his guilty plea to burglary and gross sexual imposition. He claimed that no judgment of conviction and sentence had been imposed on him regarding the indicted offenses of rape and aggravated burglary, rendering his prison sentence void.Mitchell's petition was initially reviewed by the Third District Court of Appeals, which dismissed his petition. The court concluded that Mitchell failed to raise a claim cognizable in habeas corpus and failed to show that his prison sentence had expired. It also noted that Mitchell had adequate remedies in the ordinary course of the law to raise his claims.The case was then reviewed by the Supreme Court of Ohio. The court affirmed the judgment of the Third District Court of Appeals, dismissing Mitchell's petition for a writ of habeas corpus. The Supreme Court found that the Portage County trial court had subject-matter jurisdiction to accept Mitchell’s guilty plea to burglary and gross sexual imposition and to sentence him accordingly. Any defects in the trial court’s sentencing entry were deemed to implicate the trial court’s exercise of jurisdiction over Mitchell’s criminal case, not the court’s subject-matter jurisdiction. The court also noted that Mitchell had adequate remedies, which he pursued. Therefore, the court concluded that the dismissal of Mitchell's petition was correct based on adequate-remedy grounds. View "State ex rel. Mitchell v. Fredrick" on Justia Law

The case involves a dispute over child support between Deborah Belleville and David Ayers, who were married in 2006 and had three children. In July 2019, Belleville filed for divorce. At the time, both parties were employed with comparable incomes. However, in February 2020, Ayers lost his job due to organizational changes at his company, CSX Transportation, and remained unemployed at the time of the final divorce hearing in late 2020. Ayers testified that he was seeking employment but that the job market was very small due to the COVID-19 pandemic. Belleville, on the other hand, believed that Ayers could get a new job.The trial court issued an order in December 2020, designating Belleville as the residential parent and legal custodian of the children and ordering Ayers to pay child support. The court calculated child support based on the "potential income" of Ayers, who was unemployed. The court imputed potential income to Ayers based on his previous earnings at CSX. Ayers appealed the trial court's judgment, arguing that the court had erred in imputing his potential income for child-support purposes.The Supreme Court of Ohio held that the domestic-relations court must expressly find that a parent is voluntarily unemployed or underemployed as a condition precedent to imputing potential income for child-support-calculation purposes. The court found that the trial court had failed to make an express determination of voluntary unemployment, which was a reversible error. Therefore, the court reversed the judgment of the Sixth District Court of Appeals and remanded the case to the trial court for further proceedings. View "Ayers v. Ayers" on Justia Law

The case involves Damon L. Taylor, who was charged with felony murder in the adult court after the juvenile court found probable cause to believe that Taylor was complicit in a murder. The adult court convicted Taylor of felony murder, but the Tenth District Court of Appeals vacated the conviction, arguing that the adult court lacked jurisdiction to convict Taylor of felony murder as the juvenile court had not found probable cause for that specific offense. The appellate court also ruled that Taylor's statements to the police should have been suppressed as his Sixth Amendment right to counsel had been violated.The Supreme Court of Ohio disagreed with the appellate court's decision. The Supreme Court held that the adult court did have jurisdiction over the felony-murder charge against Taylor. The court reasoned that the felony-murder charge was rooted in the same acts and events as the complicity-to-commit-murder charge, which was the subject of the juvenile complaint. Therefore, under former R.C. 2151.23(H), the adult court had jurisdiction over the felony-murder charge.Regarding Taylor's Sixth Amendment right to counsel, the Supreme Court held that this right did not attach until a criminal prosecution had commenced, which occurred after the police interrogated Taylor. Therefore, the state did not violate Taylor's Sixth Amendment right to counsel when it interviewed him in the absence of his attorney. Even if the Sixth Amendment right to counsel had attached, Taylor validly waived it when he relinquished his Fifth Amendment right to counsel after he received the Miranda warnings.The Supreme Court reversed the judgment of the Tenth District Court of Appeals and remanded the matter to that court for further proceedings. View "State v. Taylor" on Justia Law

The case revolves around Fadi Salem, who was convicted of third-degree-misdemeanor sexual imposition in February 2021. As per Ohio law, this conviction classified him as a Tier I sex offender, requiring him to register and report to the sheriff. However, the judgment entry of conviction did not explicitly state this classification. Salem later filed a motion to terminate his Tier I sex-offender classification and registration requirements, arguing that the initial judgment did not impose this classification. The trial court denied this motion and issued a nunc pro tunc judgment entry designating Salem a Tier I sex offender.Salem appealed the trial court's denial of his motion to the Twelfth District Court of Appeals. The court of appeals upheld the trial court's decision, stating that the trial court had provided Salem with the required notice of his Tier I sex-offender classification and registration requirements during the sentencing hearing. The court also held that the trial court was permitted to issue a nunc pro tunc judgment entry reflecting the imposition of the Tier I classification.While his appeal was pending, Salem filed a complaint for a writ of mandamus in the court of appeals, asking for a writ compelling the sheriff to enforce the initial judgment without the Tier I sanction. The court of appeals dismissed this complaint, stating that Salem's appeal was an adequate remedy that precluded relief in mandamus.The Supreme Court of Ohio affirmed the judgment of the Twelfth District Court of Appeals. The court held that Salem's appeal from the trial court's judgment denying his motion to terminate his Tier I sex-offender classification and registration requirements was an adequate remedy. The court also noted that the fact that Salem's appeal was unsuccessful did not render that remedy inadequate. View "State ex rel. Salem v. Jones" on Justia Law

The case revolves around the appellant, Jeffery Woods, who filed a legal malpractice lawsuit in the Hamilton County Court of Common Pleas. The defendant in the lawsuit filed a motion to dismiss the suit. Woods then attempted to remove the lawsuit to the United States District Court for the Southern District of Ohio. However, a United States magistrate judge recommended denying Woods's petition for removal and remanding the matter back to the state court. The federal court eventually adopted this recommendation. Meanwhile, before the federal court had ruled on Woods's objections, Judge Heekin of the Hamilton County Court of Common Pleas granted the motion to dismiss Woods's legal malpractice lawsuit.Woods then filed a complaint for a writ of mandamus against Judge Heekin in the First District Court of Appeals, arguing that the common pleas court lacked jurisdiction over his legal malpractice lawsuit once he filed his notice of removal to federal court. He sought an order for Judge Heekin to vacate the judgment of dismissal. Judge Heekin filed a motion to dismiss Woods's mandamus complaint, arguing that Woods did not perform the necessary steps for effecting removal to federal court, and thus the common pleas court still had jurisdiction. The court of appeals dismissed Woods's mandamus complaint, but not for the reasons set forth in Judge Heekin’s motion. Instead, the court of appeals dismissed the complaint on the basis that “mandamus cannot be used to compel a particular ruling from a judge.”The Supreme Court of Ohio affirmed the court of appeals' judgment, but disagreed with its reasoning. The Supreme Court held that if Woods was correct that Judge Heekin patently and unambiguously lacked jurisdiction to dismiss the legal-malpractice action, a writ of mandamus would be an appropriate remedy. However, the Supreme Court found that Woods did not complete all the necessary steps for removal to federal court, and thus the common pleas court did not patently and unambiguously lack jurisdiction to dismiss the legal-malpractice action. Therefore, the dismissal of Woods's mandamus complaint was correct. View "State ex rel. Woods v. Heekin" on Justia Law

The case revolves around Deonta Boyd, an inmate at the Richland Correctional Institution, who pleaded guilty in 2006 to aggravated murder with a firearm specification, felonious assault, and aggravated burglary. The trial court accepted Boyd's pleas and sentenced him to life imprisonment with parole eligibility after 41 years. Boyd did not appeal his convictions or sentence but has attempted unsuccessfully to withdraw his guilty pleas multiple times. In March 2023, Boyd filed a complaint for a writ of prohibition, claiming that the trial court violated his rights under the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution and their counterparts in the Ohio Constitution. He alleged that the trial court failed to inform him that he was waiving his constitutional right to compulsory process at the 2006 plea hearing.The Sixth District Court of Appeals dismissed Boyd's prohibition complaint, holding that Boyd could have challenged any defect in the plea colloquy on direct appeal and that any issue concerning the trial court’s alleged failure to advise him of his right to compulsory process is therefore barred by res judicata. Boyd appealed the dismissal of his complaint.The Supreme Court of Ohio affirmed the Sixth District Court of Appeals' judgment. The court found that Boyd had adequate remedies in the ordinary course of the law to raise his claim, including a direct appeal, a petition for postconviction relief, and a motion to withdraw his guilty pleas. The court also found that the trial court did not patently and unambiguously lack subject-matter jurisdiction to convict him. Therefore, Boyd was not entitled to a writ of prohibition, and the Sixth District correctly dismissed the prohibition action. View "State ex rel. Boyd v. Tone" on Justia Law