Justia Ohio Supreme Court Opinion Summaries

In this appeal, Navistar, Inc. claimed it was due a credit against the new commercial-activity tax (CAT), which was enacted to replace to replace the existing corporate-franchise and personal property taxes for industrial corporations like Navistar. In 2007, Navistar, Inc. undertook a restatement of its 2004 financial restatement, which increased Navistar’s valuation allowance from 62.4 percent to 100 percent. As a consequence, the tax commissioner reduced the amount of Navistar’s potential CAT credit from over $27 million to zero. The Board of Tax Appeals (BTA) affirmed the tax commissioner’s decision. The Supreme Court vacated the BTA’s decision, holding that the tax commissioner’s use of Navistar’s restated valuation allowance as the basis for the final determination was justified only if the restate valuation allowance was a correction of error, which could be the case here only if Navistar’s original valuation allowance was not in compliance with generally accepted accounting principles (GAAP). Remanded for a determination of whether the original valuation allowance was in compliance with GAAP based upon all the evidence in the record. View "Navistar, Inc. v. Testa" on Justia Law

This case stemmed from alleged acts of pre-leasing housing discrimination that resulted in alleged emotional distress. At the relevant time, the defendants in the underlying case (“Insureds”) were covered under an umbrella insurance policy issued by Insurer. After Insureds settled the underlying case, Insureds sued Insurer for breach of contract for failing to defend Insureds pursuant to the umbrella policy. A federal trial court granted summary judgment in favor of Insurer on its duty to defend and indemnify Insureds under the umbrella policy. The federal court of appeals reversed. At issue before the Supreme Court was whether the umbrella policy’s intentional-acts exclusion - through application of the inferred-intent doctrine - obviated Insurer’s duty to defend in this case. The Supreme Court affirmed, holding (1) the umbrella policy at issue here arguably provides coverage for emotional-distress damages through its coverage for humiliation; and (2) emotional-distress damages are not inherent in a claim for discrimination, and therefore, the inferred-intent doctrine was inapplicable. View "Granger v. Auto-Owners Ins." on Justia Law

Appellant filed a motion to suppress in his criminal action. Judge Deena R. Calabrese overruled the motion in open court and indicated that she would journalize an entry on the same day. Appellant later filed this action for a writ of mandamus to compel Judge Calabrese to journalize her decision denying the motion to suppress, alleging that the entry was never filed and that he had a right to have the oral decision reduced to writing. The court of appeals granted Judge Calabrese’s motion for summary judgment. The Supreme Court affirmed, holding that the court of appeals (1) correctly found that Appellant failed to comply with Ohio Rev. Code 2969.25(C); and (2) properly granted summary judgment because Judge Calabrese had, in fact, filed an entry on the motion to suppress that sufficiently journalized her decision overruling Jackson’s motion and therefore rendered Jackson’s action in mandamus moot. View "State ex rel. Jackson v. Calabrese" on Justia Law

Christopher Reeves, a federal inmate, sued in mandamus seeking a writ compelling the production of certain records. In his complaint, Reeves alleged that he made a public-records request of the chief of police of the Cedar Point Police Department. Along with his complaint, Reeves filed an affidavit of indigence. The court of appeals dismissed the case because Reeves’s affidavit of indigence was not notarized or accompanied by the certificate of a prison officer verifying Reeves’s lack of funds. The Supreme Court affirmed on the basis that Reeves failed to file a notarized affidavit in support of his request for a waiver of fees and because his complaint for a writ of mandamus was not verified. View "State ex rel. Reeves v. Chief of Police" on Justia Law

Appellant, an inmate, was convicted of robbery, aggravated robbery, felonious assault, and other charges. Judge David Fais first sentenced Appellant in 2001. In 2002, the court of appeals reversed and remanded for resentencing. In 2003, Judge Fais again sentenced Appellant. The court of appeals again remanded for resentencing after Appellant’s second and third appeals. In 2006, Judge Fais issued a judgment entry sentencing Appellant for a fourth time. Appellant did not appeal but, instead, filed this action in procedendo, requesting a writ ordering Judge Fais to hold a sentencing hearing in compliance with the court of appeals’ 2002 judgment. The court of appeals granted summary judgment for Judge Fais, concluding that Appellant had an adequate remedy in the ordinary course of law by way of appeal of Judge Fais’s 2006 judgment entry. The Supreme Court affirmed, holding that Appellant was not entitled to a writ of procedendo, as Judge Fais’s 2006 judgment entry sentencing Appellant to prison was an appealable order. View "State ex rel. Elkins v. Fais" on Justia Law

In 1970, Appellant pleaded guilty to aggravated assault and was sentenced to an indeterminate period. Appellant was placed in the custody of the Ohio Department of Rehabilitation and Correction (ODRC), which treated his sentence as a one-to-five-year term authorized by former Ohio Rev. Code 2901.241. The Adult Parole Authority (APA) and the Bureau of Sentence Computation (BOSC) made decisions regarding Appellant’s parole eligibility and release based on the one-to-five-year term. Appellant filed this action in mandamus requesting that Appellees - the ODRC, APA, and BOSC - remove the invalid sentence from their records and no longer make decisions based on it because the sentencing entry did not explicitly set forth the maximum and minimum length of his sentence and that the ODRC, not a court, imposed a sentence of one to five years. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant had adequate remedies in the ordinary course of the law to challenge the sentence and ODRC’s interpretation of the sentence. View "Turner v. Dept. of Rehab. & Corr." on Justia Law

Appellant, an inmate, was convicted of aggravated burglary and rape. Appellant filed this action in habeas corpus alleging that his convictions and sentence were invalid and he must be released. Specifically, Appellant alleged that the trial court had declared a mistrial in a third retrial but failed to place that declaration in a journal entry, and therefore, the trial court did not have jurisdiction over him for a fourth trial. The court of appeals dismissed the action. The Supreme Court affirmed, holding (1) res judicata barred Appellant’s habeas corpus petition because Appellant had filed at least one previous petition for habeas corpus; and (2) Appellant had an adequate remedy in the ordinary course of the law. View "Bevins v. Richard" on Justia Law

In 2005, Petitioner was convicted of first-degree-felony aggravated burglary and sentenced to six years in prison. After Petitioner was released an placed on postrelease control, he was found guilty of violating the conditions of his release and sentenced to a 150-day prison term. Petitioner subsequently filed a petition for writ of habeas corpus. The court of appeals dismissed the petition sua sponte for failure to comply with the requirement that Petitioner file a copy of his commitment papers with his petition. Petitioner appealed. Thereafter, Petitioner was released from prison under supervision. The Supreme Court affirmed the dismissal by the court of appeals, holding that, because Petitioner was no longer incarcerated, his petition was moot. View "Holloman v. Mohr" on Justia Law

The Metamore Elevator Company filed complaints with the Fulton County Board of Revision (BOR) seeking to reduce the property value of two parcels and to remove grain storage bins from the real property assessment, claiming that they were business fixtures and thus should be classified as personal property not subject to real estate tax. The BOR left the assessed valuation unchanged. The Board of Tax Appeals (BTA) reversed, concluding that the storage bins were temporary structures and should be classified as personal property. The Supreme Court affirmed, holding that the BTA correctly applied the statues when it found that the grain storage bins were personal property. View "Metamora Elevator Co. v. Fulton County Bd. of Revision" on Justia Law

In 1989, Petitioner, a prisoner at Grafton Correction Institution, was convicted of aggravated murder and other crimes. After a hearing in 2005, the parole board denied Petitioner parole. The board later determined that it should not have held the parole hearing because Petitioner had not yet served his minimum sentence at that time. Therefore, the board vacated its 2005 decision and continued Petitioner’s parole eligibility to 2015. In 2014, Petitioner filed this original action against the warden, claiming that the parole board violated his due process rights by vacating its 2005 decision. The warden filed a motion for summary judgment under Ohio R. Civ. P. 56(C). The court of appeals granted the motion for summary judgment. The Supreme Court affirmed, holding that the court of appeals (1) did not err by ruling on Petitioner’s motion for summary judgment under the Rules of Civil Procedure; and (2) properly granted summary judgment to the warden based on res judicata, as a habeas corpus action filed by Petitioner in 2013 was virtually identical to the complaint in this case. View "Brooks v. Kelly" on Justia Law