Justia Ohio Supreme Court Opinion Summaries

Appellee challenged the auditor’s valuation of a parcel of residential real estate for tax year 2012. The Columbus City Schools Board of Education (school board) sought retention of the auditor’s valuation. The Franklin County Board of Revision dismissed the complaint. Appellee appealed to the Board of Tax Appeals (BTA) from the dismissal order. On the notice of appeal, Appellee marked “yes” in response to a question asking whether the case should be referred to the small-claims docket. Accordingly, the case was placed on the small-claims docket. The school board filed a motion to return the case to the regular docket. The BTA denied the motion. The Supreme Court exercised its jurisdiction to review the interim order and affirmed the BTA’s denial of the school board’s motion, holding that the BTA did not err in denying the school board’s motion to have the case returned to the BTA’s regular docket. Remanded. View "Megaland GP, LLC v. Franklin County Bd. of Revision" on Justia Law

Appellant filed a public-records mandamus case in the court of appeals to obtain records she had requested from the City of South Euclid. During the litigation, the City and its employee (collectively, Appellees) produced all of the requested records. The court of appeals granted Appellees’ motion for summary judgment and denied Appellant’s request for statutory damages and attorney fees. The Supreme Court concluded that Appellant was entitled to damages and remanded with instructions to determine damages. On remand, the court of appeals awarded damages. Thereafter, Appellant filed a motion for sanctions against Appellees and their counsel. The court of appeals denied the motion. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion in determining that the motion for sanctions was untimely and that the actions of Appellees and their counsel in defending the case were not taken in bad faith or with the purpose of delay. View "State ex rel. DiFranco v. City of S. Euclid" on Justia Law

Relator requested public records from the City of South Euclid and its employee (together, South Euclid) for, inter alia, financial records associated with several city-owned properties. South Euclid sent some, but not all, of the requested records. Relator later filed this action seeking a writ of mandamus and statutory damages under the public-records act, alleging that South Euclid only partially responded to her requests and did not produce the records that she did receive within a reasonable period of time. The Supreme Court issued a writ of mandamus ordering that responsive records be produced if they exist and have not yet been produced and awarded costs and statutory damages in the amount of $600 to Relator, holding that South Euclid took an unreasonable amount of time producing some records responsive to Relator’s request. View "State ex rel. DiFranco v. City of S. Euclid" on Justia Law

In 1998, Defendant was convicted of aggravated murder and sentenced to death. Defendant later sought habeas corpus relief, alleging that he had received ineffective assistance of counsel at trial. The federal court granted relief, concluding that Defendant had received ineffective assistance of trial counsel during the mitigation phase of his trial. After a new mitigation hearing over which a new judge presided, twelve new jurors recommended a sentence of death. The trial court again imposed a death sentence. The Supreme Court vacated the sentence of death and remanded for resentencing, holding (1) there were no significant procedural defects in the new mitigation hearing; but (2) pursuant to the Court’s independent evaluation of the sentence under Ohio Rev. Code 2929.05(A), the aggravating circumstances that Defendant was found guilty of committing did not outweigh beyond a reasonable doubt the mitigating factors. Remanded for resentencing. View "State v. Johnson" on Justia Law

In 2010, Steak ’n Shake filed a complaint seeking a reduction for tax year 2009 from the auditor’s valuation of a Steak ’n Shake restaurant. The Warren County Board of Revision retained the auditor’s original valuation for the property. Stake ’n Shake appealed to the Board of Tax Appeals (BTA). At the BTA hearing, the property owner presented an appraisal report and testimony from a longtime state-certified appraiser, while the county presented an appraisal prepared by an employee of the county’s valuation consultant. The BTA adopted the county’s valuation. The Supreme Court reversed, holding (1) Steak ’n Shake’s objections to the competency and lack of independence of the county’s appraiser are rejected; but (2) the BTA erred in its acceptance of the county appraiser’s reliance on encumbered comparable properties in determining the value of the subject property, which is occupied by its owner. Remanded. View "Steak 'n Shake, Inc. v. Warren County Bd. of Revision" on Justia Law

In 2011, Donald Beck filed complaints against the auditor’s tax-year-2010 valuations of three two-family residential rental properties in Columbus. The Franklin County Board of Revision approved a reduction in the auditor’s original valuation based upon an unspecific sales-comparison and income approach. The Board of Tax Appeals (BTA) affirmed the reduction. The Columbus City Schools Board of Education (BOE) appealed, arguing that the BTA improperly affirmed the reduced valuation when the evidence for the reduction was not in the record. The Supreme Court affirmed the decision of the BTA, holding that the BOE waived its claim of error because it presented neither argument nor evidence before the BTA. View "Columbus City Schs. Bd. of Educ. v. Franklin County Bd. of Revision" on Justia Law

Mother and Father, who never married, were the parents of Daughter. Mother later moved to New Jersey with Daughter. When Father’s first application to determine custody of Daughter in the Cuyahoga County Juvenile Court was unsuccessful, Father filed a second application to determine custody. Mother filed an application in a New Jersey family court to transfer jurisdiction to New Jersey. The New Jersey family court denied Mother’s application and ordered that Ohio retain jurisdiction, concluding that Ohio had home-state jurisdiction under the Uniform Child Custody Jurisdiction and Enforcement Act (UCCJEA). Mother sought a writ of prohibition, asserting that the case should proceed in New Jersey. The court of appeals denied the writ. The Supreme Court affirmed, holding (1) Mother was ineligible for a writ of prohibition because the jurisdiction issue was litigated in both Ohio and New jersey, and both courts concluded that Ohio was Daughter’s home state for purposes of the UCCJEA; and (2) moreover, Mother had an adequate remedy by way of appeal of both the Ohio and New Jersey decisions regarding jurisdiction, as well as the juvenile court’s custody decision. View "State ex rel. M.L. v. O'Malley" on Justia Law

Employee was injured during the course of his employment with Precision Steel Services, Inc. Employee received compensation for his medical expenses and lost wages. Two years after the accident, Employee applied for an additional award for violation of a specific safety requirement (VSSR). The Industrial Commission granted a VSSR award to Employee, determining that Precision Steel violated the safety regulations in Ohio Adm. Code 4123:1-5-14(G)(1) and 4123:1-5-15(B) and that those violations proximately caused Employee’s injury. Precision Steel then filed this mandamus action. The court of appeals issued a limited writ, concluding that Precision Steel violated Ohio Adm. Code 4123:1-5-15(B) and ordering that the Commission readjudicate Employee’s claim based on Ohio Adm. Code 4123:1-5-14(G)(1). The Supreme Court reversed and granted a writ of mandamus requiring the Commission to vacate its order and to issue a new order denying Employee’s application for an additional award for VSSR, holding (1) neither Ohio Adm. Code 4123:1-5-14(G) nor 4123:1-5-15(B) establishes a specific safety requirement in the context of this case; and (2) therefore, the Commission’s decision that Precision Steel violated the rules was an abuse of discretion. View "State ex rel. Precision Steel Servs., Inc. v. Indus. Comm’n" on Justia Law

Pilkington North America, Inc. entered into a social contract with Toledo Edison Company under which Toledo provided one of Pilkington’s facilities with discounted electric service. The Public Utilities Commission approved the special contract. Pilkington later filed a complaint alleging that Toledo Edison had unlawfully terminated the special contract. Five other companies that also had special contracts with the utility also filed complaints against Toledo Edison. The Commission consolidated the six complaints and dismissed them. With the exception of Pilkington, each of the industrial customers appealed the Commission’s decision. The Supreme Court reversed the Commission’s order, concluding that Toledo Edison had prematurely terminated the special contracts. Pilkington subsequently filed a Ohio R. Civ. P. 60(B) motion for relief from judgment with the Commission seeking relief from the Commission’s order dismissing its complaint and its order denying the application for rehearing that the other five complainants filed. The Commission denied Pilkington’s motion, concluding that Pilkington may not use Rule 60(B) as a substitute for appeal. The Supreme Court affirmed, holding that because Pilkington did not appeal the Commission’s adverse judgment, that judgment is final, and res judicata precludes the use of Rule 60(B) to obtain relief from that final judgment. View "In re Complaint of Pilkington N. Am., Inc." on Justia Law

Defendant pled guilty to one count of unlawful sexual conduct with a minor who was over thirteen but less than sixteen years of age. Defendant, who was twenty-one years old when he committed the offense, was designated a Tier II sex offender/child-victim offender and was required to register with the county sheriff and to verify his residence address every 180 days for twenty-five years. Defendant appealed, arguing that the Tier II sex-offender requirements imposed upon him violated the Eighth Amendment’s prohibition against cruel and unusual punishment. The court of appeals affirmed. The Supreme Court affirmed, holding that the registration and address-verification requirements for Tier II offenders under Ohio Rev. Code 2950 do not constitute cruel and unusual punishment. View "State v. Blankenship" on Justia Law