Justia Ohio Supreme Court Opinion Summaries

Mary Siegel, a registered elector, filed a challenge to the voter registration of Randy Simes. The Board of Elections voted to reject the challenge. Barbara Holwadel and Steven Johnson (together, Holwadel) subsequently filed an action in the court of appeals seeking a writ of mandamus overturning the board’s decision. The court of appeals denied the writ, concluding that Holwadel failed to establish by clear and convincing evidence that the Board had a clear legal duty to strike Simes from the voter rolls. The Supreme Court affirmed, holding (1) the court of appeals correctly refused to dismiss this case for lack of standing; and (2) the court of appeals properly refused to grant a writ of mandamus compelling the Board of Elections and its members to remove Simes from the voter rolls. View "State ex rel. Holwadel v. Hamilton County Bd. of Elections" on Justia Law

Craig Conley faxed a letter to Judge Dixie Park requesting full and legible copies of documents from the court’s electronic docket. Judge Park returned the request, stating that the court did not accept faxed filings without the court’s prior approval. Conley responded that his request was not a filing but a public-records request. Conley subsequently filed this action requesting a peremptory or alternative writ of mandamus ordering Judge Park to provide the copies of the requested records. Before Judge Park responded to the complaint and before twenty-eight days had elapsed the court of appeals issued a peremptory writ and closed the case. Judge Park filed a motion for relief from judgment and then filed an appeal to the Supreme Court. The court of appeals concluded that, because of the appeal, it was without jurisdiction to rule on the motion for relief from judgment unless the case was remanded. Conley moved the Supreme Court to remand the case. The Supreme Court reversed, holding that the court of appeals acted prematurely before allowing Judge Park to answer or otherwise respond to the complaint. Remanded. View "State ex rel. Conley v. Park" on Justia Law

In 1994, Appellant was injured in the course and scope of his employment. In 2010, during the course and scope of his employment for a new employer, Appellant was injured. In 2012, Appellant requested temporary-total-disability compensation for the period beginning December 8, 2011. The Industrial Commission denied compensation, concluding that Appellant had not presented persuasive medical evidence establishing that Appellant’s 1994 industrial injury rendered him temporarily and totally disabled as of December 8, 2011. Appellant filed a complaint seeking a writ of mandamus that would require the Commission to vacate its order denying compensation and to award temporary-total-disability benefits beginning December 8, 2011. The court of appeals denied the writ. The Supreme Court affirmed, holding that the Commission did not abuse its discretion when it denied Appellant’s request for compensation for the period beginning December 8, 2011. View "State ex rel. Ritzie v. Reece-Campbell, Inc." on Justia Law

A landowner filed a complaint for breach of contract against the predecessor in interest to Huntington National Bank. The trial judge ruled in favor of the landowner and awarded damages. The court of appeals reversed on the issue of the proper standard for calculating damages and remanded the case for a recalculation. On remand, the trial judge ordered a new evidentiary hearing on damages, concluding that the court could not arrive at a proper measure of damages without additional testimony. Huntington filed this action in procedendo and prohibition in the court of appeals and filed a notice of appeal of the trial court’s order. The court of appeals (1) dismissed the appeal on grounds that the order requiring a new hearing was not a final appealable order, and (2) dismissed the procedendo and prohibition petition, concluding that Huntington had an adequate remedy by way of appeal and that the trial court did not exceed its jurisdiction by ordering an evidentiary hearing. The Supreme Court affirmed, holding that Huntington had an adequate remedy at law by way of appeal and that the trial judge’s jurisdiction to order the evidentiary hearing and to determine damages based on new evidence was not patently and ambiguously lacking. View "State ex rel. Huntington Nat'l Bank v. Kontos" on Justia Law

The Ohio Republican Party (ORP) sent a public-records request to Cuyahoga County seeking the County’s key card swipe data for five individuals, including Edward FitzGerald, the County’s former county executive. At the time of the ORP’s request, the key-card-swipe data were security records exempted from release because FitzGerald had received threats and release of that data would have diminished the County’s ability to protect him and maintain the security of the office of the county executive. Subsequent to receipt of the public-records request, the County moved its administrative offices to a new building, FitzGerald’s term of office expired, and the County released the records to members of the media. The ORP filed this mandamus action alleging that the County had failed to respond to its public-record requests. The Supreme Court granted a writ of mandamus and ordered the release of the records, holding that FitzGerald’s key-card-swipe data were public records, and the County failed to demonstrate that they were exempt from disclosure. View "State ex rel. Ohio Republican Party v. FitzGerald" on Justia Law

Appellant participated in a program called the Percentage of Income Payment Plan (“PIPP”) that provided assistance to low-income residential customers. Most PIPP customers pay a fixed percentage of their monthly income rather than the actual cost of service. Appellant later left PIPP but continued to receive gas service from Vectren Energy Delivery of Ohio, Inc. at the standard rate. Appellant was reinstated in PIPP seven months after her departure. Vectren subsequently informed Appellant that she had to pay the difference between the charges she paid during the time she was not in the program and the monthly PIPP installment payments that would have been due had she remained in PIPP. Appellant filed a complaint with the Public Utilities Commission alleging that Vectren’s attempt to charge her for the missed PIPP installments was unlawful and unreasonable. The Commission found in favor of Vectren. The Supreme Court affirmed, holding that Appellant failed to demonstrate that the Commission’s orders were unreasonable or unlawful. View "Toliver v. Vectren Energy Delivery of Ohio, Inc." on Justia Law

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