Justia Ohio Supreme Court Opinion Summaries

This appeal involved Defendant’s motion to suppress evidence of a gun that was found in a search of a car legally parked on a public street that Defendant was sitting in just before his arrest on a warrant for domestic violence. After Defendant was arrested, an officer conducted an inventory search of the car, during which he found a handgun. The district court denied Defendant’s motion to suppress, concluding that there was probable cause to arrest Defendant based on the domestic-violence warrant and that, pursuant to that arrest, the inventory search of the car prior to towing was proper. The Supreme Court reversed, holding that the warrantless inventory search of the lawfully parked vehicle in this case was unreasonable under the Fourth Amendment to the United States Constitution and Ohio Const. art. I, 14. View "State v. Leak" on Justia Law

A petition was submitted to to the clerk of the Hilliard City Council to amend the city charter. The City Council voted against an ordinance to place the proposed charter amendment on the March 15, 2016 ballot. Relators sought a writ of mandamus to compel the Hilliard City Council to approve an ordinance placing a proposed city-charter amendment on the March 15, 2016 ballot. Relators subsequently commenced this original action for a writ of mandamus. The Supreme Court granted the writ, holding that the city council’s objections to the petition were unavailing, and therefore, the city council was compelled to approve the necessary ordinance to place the initiative petition on the March 15, 2016 ballot. View "State ex rel. Carrier v. Hilliard City Council" on Justia Law

Cuyahoga County filed an exemption to a tract of real property it acquired in 2004. The property consisted of a marina/restaurant that operated in conjunction with an adjacent public park. The tax commissioner granted the application as to the the public park portion but denied the application as to the remainder constituting the marina and restaurant. In doing so, the Commissioner invoked his authority to order a split between the taxable and exempt portions. The County appealed, arguing that the Commissioner erred by finding that the property was not used exclusively for a public purpose. The Board of Tax Appeals affirmed primarily on the ground that the marina and restaurant were operated “with a view to profit.” The Supreme Court affirmed, holding that when the marina and restaurant are considered separately from the park, the denial of the exemption was neither unreasonable nor unlawful. View "Cuyahoga County v. Testa" on Justia Law

In 2010, New Thistledown, LLC, which owned Thistledown Racetrack, petitioned for Chapter 11 bankruptcy relief. Thistledown was purchased at an auction for $43,000,000. The bankruptcy court authorized the sale, stating that the sale price constituted reasonably equivalent value and fair consideration of the purchased assets. For tax year 2010, the Cuyahoga County fiscal officer assigned a value of $14,264,000 to the parcels comprising Thistledown. The Board of Education of Warrensville Heights City School District filed a complaint with the board of revision (BOR) seeking an increase in valuation. The BOR retained the fiscal officer’s initial valuation. The Board of Tax Appeals (BTA) rejected the 2010 sale price as evidence of value and valued the real property at $13,800,000. The Supreme Court affirmed, holding (1) the BTA reasonably and lawfully determined that the 2010 sale did not establish the true value of Thistledown; and (2) the evidence supported the BTA’s finding that Thistledown was worth $13,800,000 as of the tax-lien date. View "Warrensville Heights City Sch. Dist. Bd. of Educ. v. Cuyahoga County Bd. of Revision" on Justia Law

Appellant challenged the aspect of Ohio’s Putative Father Registry (OPFR) that limits the time frame during which a man can register as a putative father in order to gain a right to receive notice of any subsequent adoption proceedings involving the man’s putative child. The deadline, in the version of the law that applied to Appellant, is thirty days after the child’s birth, but has since been reduced by the Legislature to fifteen days. In his complaint, Appellant contended that the deadline is unconstitutional as applied to the putative fathers of children who are relinquished for adoption more than thirty days after birth. Specifically, Appellant argued that putative fathers have a due process right to register with the OPFR at any point prior to the initiation of a child’s adoption proceedings. The trial court denied all relief requested by Appellant. The court of appeals affirmed. The Supreme Court affirmed, holding that because Appellant failed to take sufficient action to protect his legal rights or to support his constitutional challenge, he was not able to demonstrate that he was injured by the application of the statutory putative-father-registration deadline. View "In re Adoption of H.N.R." on Justia Law

In 2010, the Talawanda City School District Board of Education (BOE) filed its application to exempt property located within the district. The tax commissioner granted an exemption for all of the property except for a parcel being farmed pursuant to lease, concluding that the pecuniary benefit realized by the farmer disqualified the land from exemption because that portion was not used for school purposes. The Board of Tax Appeals affirmed. the Supreme Court reversed, holding (1) following its amendment in 2010, Ohio Rev. Code 3313.44 does not contain a restriction requiring that the property owned by the BOE be used exclusively for school purposes; and (2) the entire property described in the BOE’s application shall be exempt for the year at issue. View "Talawanda City Sch. Dist. Bd. of Educ. v. Testa" on Justia Law

Defendant was convicted of tampering with evidence for concealing heroin within a body cavity. The court of appeals affirmed Defendant’s tampering conviction, concluding that at the time Defendant concealed the heroin in her body cavity, Defendant had constructive knowledge of an impending investigation. At issue on appeal was whether a person who hides evidence of a crime that is unmistakable to him or her commits tampering with evidence in the absence of evidence that a victim or the public would report a crime. The Supreme Court reversed, holding (1) Ohio law does not impute constructive knowledge of an impending investigation based solely on the commission of an offense, and therefore, the fact that an act was unmistakably a crime does not in itself establish that the defendant knew of an investigation into that crime or that such an investigation was likely to be instituted; and (2) in this case, Defendant’s tampering conviction was not supported by sufficient evidence because there was no evidence that, at the time she concealed the heroin in her body, Defendant knew or could have known that a state trooper would stop her car and begin an investigation of her for drug trafficking and drug possession. View "State v. Barry" on Justia Law

Appellees damaged their vehicle when they collided with a deer in the roadway. Appellant insured the vehicle. Appellees had their vehicle repaired using aftermarket replacement parts that were not produced by the original equipment manufacturer (OEM). Appellant, however, refused to pay for OEM parts after providing an estimate that was based on the use of non-OEM parts. Appellees filed a complaint alleging eight causes of action related to Appellant’s estimate and its refusal to pay for OEM parts. The trial court granted summary judgment to Appellees on their claim that Appellant violated the Consumer Sales Practices Act by failing to obtain one of Appellees’ signatures on the bottom of the estimate, and Appellees voluntarily dismissed the remainder of their claims. The trial court awarded Appellees actual damages, statutory treble damages, attorney fees, and expenses. The court of appeals modified and affirmed the trial court’s award of damages. The Supreme Court vacated the judgment of the court of appeals and dismissed the cause, holding that Appellant’s provision of a repair estimate to Appellees was not in connection with a consumer transaction and, therefore, was not an “unfair or deceptive act or practice” pursuant to Ohio Rev. Code 1345.02. View "Dillon v. Farmers Ins. of Columbus, Inc." on Justia Law

At issue in this appeal was a 2010 assessment of personal property issued by the Pike County auditor against Lockheed Martin Energy Systems, Inc. (LMES) for tax year 1993. The tax commissioner canceled the assessment. LMES prevailed before the Board of Tax Appeals (BTA) on appeal. LMES prosecuted its appeal to the Supreme Court based on the BTA’s failure to address its contentions that the auditor issued the assessment frivolously and in bad faith. The county auditor cross-appealed. The Supreme Court affirmed, holding (1) the BTA lacked the authority to make a finding of frivolous conduct or bad faith on the auditor’s part; (2) LMES had standing as an aggrieved party to prosecute its appeal to the Supreme Court; and (3) the tax commissioner properly canceled the assessment, as affirmed by the BTA, because LMES was never shown to qualify as a “taxpayer” as that term is statutorily defined for purposes of the personal property tax. View "Snodgrass v. Testa" on Justia Law

Relator was indicted on two counts of felonious assault and one count of aggravated burglary. One of the felonious-assault counts was subsequently amended. After a jury trial, Relator was convicted of aggravated burglary and one count of felonious assault, the jury being unable to reach a verdict as to the amended felonious-assault count. The sentencing entry did not dispose of the amended felonious-assault charge. The state later indicted Relator on two new charges under the same case number. The sentencing entry memorializing a plea deal involving the posttrial indictments failed to address the unresolved felonious-assault charge from trial. The trial judge finally signed an entry dismissing the felonious-assault charge, but the court’s order dismissed the charge “as indicted,” without disposing of the charge as amended before trial. Relator sought a writ of mandamus compelling the issuance of a final, appealable order in his criminal case. The County filed a motion to dismiss based on res judicata. The Supreme Court denied the County’s motion to dismiss - as res judicata did not apply where the trial court never issued a final, appealable order - and issued a peremptory writ directing the County to issue a final, appealable order disposing of all the charges against Relator. View "State ex rel. McIntyre v. Summit County Court of Common Pleas" on Justia Law