Justia Ohio Supreme Court Opinion Summaries
Lycan v. Cleveland
Named Plaintiffs filed an amended class-action complaint challenging the city of Cleveland’s imposition of fines against vehicle lessees. The trial court granted Cleveland’s motion for judgment on the pleadings, concluding that Plaintiffs had waived the right to pursue judicial remedies by paying their fines and failing to appeal their citations. The trial court also denied Plaintiffs’ class-certification motion. The court of appeals reversed and remanded. On remand, the trial court granted partial summary judgment for Plaintiffs. The court also granted class certification. Cleveland appealed the class certification order, arguing that res judicata precluded class relief. The court of appeals affirmed, concluding that Plaintiffs’ failure to appeal their traffic violations through Cleveland’s administrative process did not bar them from pursuing equitable and declaratory relief in the trial court. The Supreme Court vacated in part the judgment of the court of appeals, holding that the court of appeals erred in deciding that res judicata barred Plaintiffs’ claims, in the absence of a final, appealable order from the trial court addressing that question. Remanded. View "Lycan v. Cleveland" on Justia Law
Posted in:
Class Action
State ex rel. Stewart v. Russo
A jury found Appellant guilty of aggravated murder, attempted murder, aggravated robbery, and kidnapping. The trial court imposed a sentence of life imprisonment without parole eligibility for thirty years for the aggravated-murder conviction. Appellant later filed a motion for a final, appealable order and resentencing, arguing that because his sentencing entry did not state the reasons why the mitigating factors outweighed the aggravating circumstances, it was not a final, appealable order. The trial court denied the motion, concluding that it was not required to file a written sentencing opinion where the jury recommended a sentence other than death. Thereafter, Appellant filed a petition for a writ of mandamus seeking an order compelling Judge Judge Michael Russo to issue a separate sentencing opinion. The court of appeals dismissed Appellant’s complaint for writ of mandamus. The Supreme Court affirmed, holding that Appellant did not have a clear legal right to a separate sentencing opinion and that the Judge Russo did not have a clear legal duty to provide one. View "State ex rel. Stewart v. Russo" on Justia Law
Posted in:
Criminal Law
Lowe’s Home Ctrs., Inc. v. Washington County Bd. of Revision
In 2010, the Washington County Auditor determined a value of $9,091,000 for a Lowe’s Home Center store in Marietta. Lowe’s filed a complaint before the Washington County Board of Revision (BOR) seeking a reduction to $3,600,000. The BOR retained the auditor’s valuation. On appeal, Lowe’s and the County presented competing appraisals. The Board of Tax Appeals (BTA) adopted the County’s appraisal, concluding that the County’s comparables were more appropriate. Lowe’s appealed, arguing that the BTA misapplied the Supreme Court’s decision in Meijer Stores Ltd. Partnership v. Franklin County Bd. of Revision by adopting the type of appraisal in this case that the BTA rejected in Rite Aid of Ohio, Inc. v. Washington County Bd. of Revision. The Supreme Court explained the significance of Meijer Stores in its decision in the Rite Aid appeal, also issued today. The Supreme Court vacated the BTA’s decision in the instant case, holding that reading the BTA decision in light of that explanation identified a significant omission in the BTA’s analysis. Remanded. View "Lowe's Home Ctrs., Inc. v. Washington County Bd. of Revision" on Justia Law
Rite Aid of Ohio, Inc. v. Washington County Bd. of Revision
The 2010, the Washington County Auditor determined a value of $3,319,000 for multiple parcels that together constituted a Rite Aid drugstore and its parking lot. Rite Aid of Ohio, Inc. filed a complaint before the Washington County Board of Revision (BOR) seeking a reduction. The BOR retained the auditor’s valuation. On appeal, Rite Aid and the County presented competing appraisals. The County’s appraisal was more than twice that of Rite Aid’s. The Board of Tax Appeals (BTA) adopted Rite Aid’s appraisal as the value of the property. The Supreme Court affirmed, holding that the Supreme Court’s decision in Meijer Stores Ltd. Partnership v. Franklin County Bd. of Revision did not require the use of the kind of comparables that the County’s appraiser relied upon because Meijer Stores was not applicable in this case. View "Rite Aid of Ohio, Inc. v. Washington County Bd. of Revision" on Justia Law
State ex rel. Duclos v. Bd. of Elections
On December 1, 2015, Gary Lee filed a petition and declaration of candidacy for sheriff at the Hamilton County Board of Elections. On January 4, 2016, David Duclos filed a written protest with the Board of Elections, alleging that Lee’s application was incomplete because it did not include the result sheet of an FBI background check. During the course of a protest hearing held by the Board, the report from the FBI was entered into evidence. The Board then denied the protest. On January 14, 2016, Duclos filed a mandamus complaint but, five days later, sought to dismiss that action and filed a new complaint for a writ of prohibition. The Supreme Court denied the petition for a writ of prohibition on the grounds of laches, concluding that Duclos unreasonably delayed bringing this action to the prejudice of Respondents. View "State ex rel. Duclos v. Bd. of Elections" on Justia Law
Posted in:
Election Law
State ex rel. Old Dominion Freight Line, Inc. v. Indus. Comm’n
Robert Mason was injured while working as a truck driver for Old Dominion Freight Line, Inc. Mason later applied for permanent-total-disability compensation. The Industrial Commission of Ohio granted Mason’s application based on the reports of two Commission specialists. Old Dominion filed a complaint for a writ of mandamus that would require the Commission to vacate its award of permanent-total-disability compensation, maintaining that the reports were flawed because the doctors did not review the defense medical reports in advance of their independent medical examinations. The court of appeals denied the writ. The Supreme Court affirmed, holding (1) Old Dominion’s request to depose the doctors was not reasonable; and (2) the reports constituted some evidence of permanent total disability, and therefore, Old Dominion failed to establish a clear legal right to the relief requested and a clear legal duty on the part of the Commission to provide such relief. View "State ex rel. Old Dominion Freight Line, Inc. v. Indus. Comm’n" on Justia Law
State ex rel. Cornerstone Developers, Ltd. v. Greene County Bd. of Elections
Cornerstone Developers, Ltd. sought extraordinary relief to prevent a tax levy for Sugarcreek Township from appearing on the March 15, 2016 election ballot because it was allegedly not in compliance with state laws. The Supreme Court (1) granted in part the requested writ of mandamus, holding that the Board of Election was under a clear legal duty to remove the levy from the ballot because it was untimely; but (2) declined to issue a writ of prohibition because the Board was not engaged in a quasi-judicial function when it prepared the ballot. View "State ex rel. Cornerstone Developers, Ltd. v. Greene County Bd. of Elections" on Justia Law
Posted in:
Election Law
State ex rel. Hunter v. Dinkelacker
Relator was convicted of having an unlawful interest in a public contract and was sentenced to six months in jail. Relator sought writs of prohibition, mandamus, and habeas corpus. The Supreme Court denied the writs by ordered that Relator’s sentence be stayed pending resolution of her appeal. The court of appeals subsequently affirmed the conviction. Relator then filed a motion in the court of appeals for en banc reconsideration. Relator asked the trial court judge to stay execution of her sentence, but he declined. Thereafter, Relator filed this action for a writ of prohibition to prevent the trial court judge from executing her sentence until, among other conditions, the court of appeals decided her motion for en banc reconsideration. The Supreme Court denied the writs and dismissed the case, holding (1) because there was no order of this Court prohibiting the trial court judge from exercising judicial authority there was no basis upon which to issue a writ of prohibition to the judge; and (2) because the sheriff would not be exercising judicial authority in admitting Relator into jail, the issuance of a writ of prohibition against him would be inappropriate. View "State ex rel. Hunter v. Dinkelacker" on Justia Law
Posted in:
Criminal Law
State ex rel. Claugus Family Farm, L.P. v. Seventh Dist. Court of Appeals
These consolidated actions involved an original action in the Supreme Court and an appeal of a judgment of the court of appeals and concerned the interpretation of several nearly identical oil and gas leases. In the original action, Relator, an absent and unnamed plaintiff in a class action, challenged the court of appeals’ order tolling the leases in the class action pending appeal and sought writs of prohibition and mandamus. The appeal challenged the court of appeals’ interpretation of the leases in the class action. The Supreme Court (1) affirmed the judgment of the court of appeals in the class action, holding that the court of appeals correctly interpreted the leases; (2) denied a writ of mandamus or prohibition in the original action because Relator had an adequate remedy in the ordinary course of law by moving to intervene in the appeal and because the court of appeals did not patently and unambiguously lack jurisdiction to issue an order tolling the leases; and (3) denied the motions of the appellee in the appeal to toll the terms of the leases. View "State ex rel. Claugus Family Farm, L.P. v. Seventh Dist. Court of Appeals" on Justia Law
Posted in:
Contracts, Energy, Oil & Gas Law
State ex rel. Moir v. Kovack
Gabriella Moir was the plaintiff in the underlying divorce case. Judge Mary Kovack, the only judge in the Medina County Domestic Relations Court, recused herself from the case. Acting in her capacity as the administrative judge of that court, Judge Kovack subsequently issued orders assigning magistrates to the visiting judge, Judge Carol Dezso of Summit County Domestic Relations Court, for the purpose of presiding over the divorce. Moir brought this action for a writ of prohibition against Judge Kovack and Judge Dezso, as well as the two courts and one of the assigned magistrates, asserting that the two judges lacked jurisdiction to assign magistrates in the case. The Supreme Court granted a peremptory writ as to Judge Kovack, holding (1) because Judge Kovack recused herself based on a potential conflict of interest, she was without jurisdiction to assign magistrates in the case; and (2) Judge Dezso as the appointed judge may assign magistrates to help her hear the case. View "State ex rel. Moir v. Kovack" on Justia Law
Posted in:
Civil Procedure, Family Law