Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's complaint for a writ of mandamus requiring the Industrial Commission of Ohio to award him a scheduled award of permanent partial disability (PPD) compensation under Ohio Rev. Code 4123.57(B) for the loss of the use of his right hand, holding that the court of appeals correctly denied the writ.Appellant was injured during the course of his employment as a laborer when he fell from a roof onto concrete below. A district hearing officer granted Appellant's request for scheduled-loss compensation, but a staff hearing officer vacated that order on appeal. The court of appeals denied Appellant's ensuing complaint for a writ of mandamus. The Supreme Court affirmed, holding that some evidence supported the commission's decision denying Appellant's request for compensation for the loss of the use of his right hand, and the commission did not abuse its discretion. View "State ex rel. Block v. Industrial Commission of Ohio" on Justia Law

The Supreme Court granted a writ of mandamus ordering the Ohio Department of Rehabilitation and Correction to produce a copy of a kite that he alleged he had exchanged with the "cashier" of the North Central Correctional Complex (NCCC), where Relator was incarcerated, holding that Relator was entitled to the writ.According to Relator, an NCCC inspector denied Relator's kite request on the ground that she was not responsible for printing kites. After the department denied Relator's grievance Relator brought this mandamus action seeking production of the kite. The Supreme Court granted the writ, holding (1) Relator showed that he had a clear legal right to the requested relief and that the department had a clear legal duty to provide it; and (2) Relator was not entitled to statutory damages. View "State ex rel. Clark v. Ohio Dep't of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the decision of the court of appeals in this criminal case, holding that it does not violate the separation of powers doctrine to tie the judge's ability to reduce the registration period for a person convicted of arson to a recommendation from executive branch officials.In 2012, the General Assembly passed a law codified at Ohio Rev. Code 2909.13(A) establishing a registry of people convicted of arson-related crimes that applied to those convicted of arson or aggravated arson, as well as those convicted of a related attempt or conspiracy or complicity offense. At issue was Ohio Rev. Code 2909.15(D)(2)(b), which provides a limited exception for the lifetime-registration requirement. Defendant in this case pleaded guilty to a single count of arson, for which he was required to register annually for life. At sentencing, challenged the constitutionality of the reduced-registration provision. The trial court denied the challenge, and the court of appeals affirmed. The Supreme Court affirmed, holding that there is no separation of powers violation within Ohio's arson offender registration scheme. View "State v. Daniel" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's writ of habeas corpus arguing that the sentencing court lacked subject-matter jurisdiction over Appellant's case after it issued a final judgment in 2007, holding that the court of appeals did not err.Pursuant to a plea agreement in which Appellant agreed to testify against a potential codefendant, Appellant pleaded guilty to murder with a firearm specification and aggravated robbery. The convictions were vacated based on Appellant's failure to cooperate with prosecutors. After a jury trial, Appellant was convicted of murder aggravated robbery, and aggravated burglary and three-year firearm specifications. On appeal, Appellant argued that the sentencing court lacked subject matter jurisdiction over his case pursuant to State v. Gilbert, 35 N.E.3d 493 (Ohio 2014), after it issued final judgment in 2007. The court of appeals agreed but dismissed the petition because Appellant's 2007 convictions and sentence were still valid and his maximum sentence had not expired. The Supreme Court affirmed, holding that the court of appeals did not err in dismissing the petition because Appellant was not subject to immediate release from prison or confinement. View "Driggins v. Bracy" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Petitioner's mandamus action after recognizing his status as a vexatious litigator as declared in an earlier, separate matter, holding that Petitioner did not "continue" his proceeding as a vexatious litigator in this case.Appellant filed a mandamus action against the Franklin County Board of Commissioners and mailed his objections to a magistrate's decision to the court of appeals. The court in a separate matter subsequently declared Appellant to be a vexatious litigator. Upon filing Appellant's objections in this case, the court of appeals recognized Appellant's status as a vexatious litigator and sua sponte dismissed the case. The Supreme Court reversed, holding (1) when Appellant mailed his objections and filed his motion for leave, he did not "continue" the proceeding as a vexatious litigator under Ohio Rev. Code 2323.52; and (2) therefore, the court of appeals' dismissal was incorrect. View "State ex rel. Mobley v. Franklin County Bd. of Commissioners" on Justia Law

The Supreme Court dismissed Relator Mark Repp's quo warranto claim he sought to oust Rhonda Best from judicial office and to declare him the rightful holder of the office and dismissed all other claims sua sponte, holding that Repp was not entitled to relief.In 2019, Repp was elected to a six-year term as judge of a municipal court. Less than two years into his term, the Supreme Court found that Repp had engaged in professional misconduct and suspended him for one year from the practice of law. Because Repp failed to perform his official duties for more than six months, the judicial office he held was declared vacant, and Governor Mike DeWine appointed Best to fill the vacancy. After Repp was reinstated to the practice of law he filed this original action seeking a writ of quo warranto to oust Best from officer and also sought a writ of prohibition, declaratory judgment, and injunctive relief. The Supreme Court denied all forms of relief, holding (1) if a judge is absent from his official duties for at least six months, the appropriate legislative authority is allow to declare the judicial office vacant under Ohio Rev. Code 1901.10(B); and (2) Repp's remaining requests either failed to state a claim, or this Court lacked jurisdiction over his claims. View "State ex rel. Repp v. Best" on Justia Law

The Supreme Court denied relief in this expedited election action brought by Brandon King, mayor of East Cleveland, seeking extraordinary writs to compel the removal of a proposed East Cleveland city-charter amendment from the November 7, 2023 general election ballot and to prevent the December 5, 2023 special mayoral-recall election, holding that King was not entitled to relief.On August 9, 2023, the East Cleveland City Council passed resolution submitting to city electors a proposed revision to the city charter that would change the mayoral election from a partisan to a nonpartisan contest. The Cuyahoga County Board of Elections and its individual members (collectively, the board) voted unanimously to approve the proposed city-charter amendment for placement on the November 7 ballot as Issue 48. A city resident later submitted a petition for King's recall as mayor, and the board scheduled a December 5, 2023 special election. King submitted a written protest challenging the placement of Issue 48 on the general election ballot and placement of the mayoral-recall issue on the December 5 special-election ballot. The protest was dismissed. King subsequently filed this action seeking extraordinary relief. The Supreme Court denied relief, holding that the board did not abuse its discretion or disregard applicable law in dismissing King's protest. View "State ex rel. King v. Cuyahoga County Bd. of Elections" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals in this dispute arising out of environmental-cleanup and remediation work at two Superfund sites in Bronson, Michigan, holding that Restatement (Second) 193 does not govern the choice-of-law analysis for bad faith claims.Scott Fetzer Company filed this action asserting a breach of contract claim against certain insurance companies, including Travelers Casualty and Surety Company, alleging breaches of certain insurance contracts. Fetzer also asserted a tort claim against each company, arguing that they had acted in bad faith when handling his claims. As to Travelers, an administrative judge concluded that Ohio law applied to a discovery dispute concerning Scott Fetzer's bad faith claim. The court of appeals affirmed, determining that Ohio law governed the bad-faith discovery dispute because the cause of action was a tort. In affirming, the court applied the choice-of-law rules set forth in section 145 of the Restatement. Travelers appealed, arguing that section 193 governs the choice-of-law analysis for bad faith claims because they arise out of insurance contracts. The Supreme Court affirmed, holding that the court of appeals correctly ruled that the choice-of-law analysis applicable to a bad-faith claim as provided by section 145. View "Scott Fetzer Co. v. American Home Assurance Co." on Justia Law

The Supreme Court granted a writ of prohibition in this original action, holding that the trial court in this case lost jurisdiction to proceed on a request for attorney fees after entering final judgment.After a limited remand in this case stemming from a real estate dispute the trial court entered final judgment, and the judgment was subsequently paid. Thereafter, the prevailing parties filed a motion seeking more than $167,000 in additional attorney fees. Petitioner filed this original action seeking a writ of prohibition alleging that the common pleas court patently and unambiguously lacked jurisdiction to conduct further proceedings. The Supreme Court granted the petition, holding that the court of appeals' mandate did not give the trial court jurisdiction to entertain an attorney fees request that accrued after the final judgment. View "State ex rel. Mather v. Oda" on Justia Law

The Supreme Court affirmed the opinion of the court of appeals rejecting Charles Simpson's peremptory prohibition claim and mandamus claim, holding that the court of appeals did not err in denying the prohibition claim and that Simpson failed to state a valid claim for mandamus relief.Grande Voiture in a separate case filed a motion for an order finding Simpson, the defendant in that case, in contempt of the trial court's order granting declaratory and injunctive relief in favor of Grande Voiture. Common Pleas Court Judge Kimberly Melnick granted Grande Voiture's motion to strike Simpson's answer and counterclaim on the grounds that Grande Voiture's contempt motion was not a pleading. Simpson then filed an original action seeking a peremptory writ of prohibition forbidding the judge from proceeding with the contempt hearing without allowing a jury trial and without considering the answer and counterclaim. Simpson also requested a writ of mandamus compelling the judge to proceed by jury trial on the issues before her. The court of appeals granted the judge's motion to dismiss. The Supreme Court affirmed, holding that Simpson failed to state a valid claim for the writs. View "State ex rel. Simpson v. Melnick" on Justia Law