Justia Ohio Supreme Court Opinion Summaries

Appellant was granted a default judgment against Bank of America and filed a praecipe for a writ of execution. BAC Field Services filed a motion to stay the execution of judgment and a motion for relief from judgment. The trial court granted the motions. The court of appeals reversed and remanded the case with instructions for the trial court to clarify its reasoning. Thereafter, Appellant moved the trial court to reinstate the default judgment. When the court had not ruled on the motion, Appellant filed this action requesting writs of prohibition barring the trial court from vacating the default judgment and barring BAC from appearing in the case. The court of appeals denied the writs. After Appellant appealed, the trial court again vacated the default judgment and responded to the court of appeals’ instruction to clarify its reasoning. The Supreme Judicial Court (1) declared the petition for a writ of procedendo moot because the trial court had issued a decision clarifying its reasons for vacating the default judgment; and (2) affirmed the court of appeals’ judgment denying Appellant’s petition for writs of prohibition because the court did not patently and unambiguously lack jurisdiction to proceed. View "State ex rel. Haley v. Davis" on Justia Law

503 South Front Street, LP, a for-profit corporation, owned 30,000 square feet of commercial space and leased the property for a term of thirty years to ShadoArt Productions, a nonprofit organization. ShadoArt filed an application for exemption under Ohio Rev. Code 5709.12 and 5709.121, which statutes articulate the substantive requirements for public-use and charitable-use exemptions. The tax commissioner denied the request. The Board of Tax Appeals (BTA) affirmed. On appeal, ShadoArt argued that because Ohio Rev. Code 5715.27, which permits certain long-term lessees to file applications for exemption, authorizes it to file an application for exemption, it was also entitled to receive an exemption under sections 5709.12 and 5709.121. The Supreme Court affirmed the decision of the BTA, holding (1) amended section 5715.27 did not alter the substantive requirements for any specific exemption under chapter 5709; and (2) ShadoArt’s claim for exemption did not satisfy the requirements set forth in sections 5709.12 and 5709.121 because the property does not belong to a charitable institution. View "ShadoArt Prods., Inc. v. Testa" on Justia Law

Petitioners executed a promissory note and mortgage in favor of Mortgage Electronic Registrations Systems, Inc. The notary acknowledgment on the mortgage was left blank. The mortgage was subsequently recorded with the county recorder. The interest in the mortgage was later assigned to Bank. Thereafter, Petitioners initiated a Chapter 13 bankruptcy and commenced an adversary proceeding seeking to avoid the mortgage as defectively executed. The bankruptcy court determined that its interpretation of Ohio Rev. Code 1301.401 would be dispositive in this case and certified to the Supreme Court questions of state law concerning whether section 1301.401 has an effect on the case. The Supreme Court answered that section 1301.401 applies to all recorded mortgages in Ohio and acts to provide constructive notice to the world of the existence and contents of a recorded mortgage that was deficiently executed under Ohio Rev. Code 5301.01. View "In re Messer" on Justia Law

Rural Health Collaborative of Southern Ohio, Inc. owned a facility in Adams County that was operated under lease by Dialysis Clinic, Inc. Rural Health filed a charitable-use exemption application for the property. The tax commissioner denied the exemption. The Board of Tax Appeals (BTA) concluded that Rural Health qualified as a charitable institution under Ohio Rev. Code 5709.121(A)(2) and granted the exemption. The Supreme Court vacated the BTA’s grant of exemption and remanded, holding (1) the BTA did not abuse its discretion in determining that Rural Health qualifies as a charitable institution; but (2) BTA erred in granting the exemption because the BTA did not fully analyze the claim under Ohio Rev. Code 5709.121(A)(1). Remanded. View "Rural Health Collaborative of S. Ohio, Inc. v. Testa" on Justia Law

Plaintiffs, former correctional institution employees and a labor union, filed this action against numerous government Defendants, alleging that 2011 Am.Sub.H.B. No. 153, the budget bill for the 2012-2013 biennium, violates the Ohio Constitution. H.B. 153 modified prior law governing contracts for the private operation and management of a state correctional institution in several ways. The court of common pleas granted Defendants’ motion to dismiss, concluding (1) the court lacked jurisdiction to determine whether employees of privately owned or operated prisons were employees, as defined by Ohio Rev. Code 4117.01(C); and (2) the court had jurisdiction over the constitutional challenges to H.B. 153, but Plaintiffs failed to state a claim that H.B. 153 was unconstitutional. The court of appeals reversed in part and ordered the trial court to hold an evidentiary hearing to determine whether H.B. 153 violates the one-subject rule in Ohio Const. art. II, 15(D). The Supreme Court affirmed in part and reversed in part, holding (1) H.B. 153 is constitutional; and (2) the State Employee Relations Board has exclusive jurisdiction to determine public-employee status under section 4117.01(C). View "State ex rel. Ohio Civil Serv. Employees Ass’n v. State" on Justia Law

Defendant was charged with operating a motor vehicle under the influence of alcohol. Defendant filed a motion to suppress the evidence obtained against him, including laboratory and chemical tests of his alcohol level. The trial court granted the motion. The appellate court affirmed, ruling that the State had failed to establish substantial compliance with Ohio Adm. Code 3701-53-05(F) because it allowed a blood sample to remain unrefrigerated for four hours and ten minutes before it was placed in the mail, and therefore, Defendant’s blood-alcohol test results were inadmissible. The Supreme Court reversed, holding that the State demonstrated substantial compliance with Ohio Adm. Code 3701-53-05’s requirement that blood be refrigerated, but, in conformity with State v. Burnside, the case is remanded to provide Baker with an opportunity to rebut the presumption of admissibility. View "State v. Baker" on Justia Law

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

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

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

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