Justia Ohio Supreme Court Opinion Summaries

Alphonso Mobley Jr. filed an original action in mandamus under Ohio’s Public Records Act against Hamilton County Prosecuting Attorney Melissa A. Powers, seeking records related to former R.C. 309.16 and a records-retention schedule. He also requested awards of statutory damages and costs. The Supreme Court of Ohio granted a limited writ of mandamus in part and denied in part. The court denied the writ as moot concerning some of the requested records, granted a limited writ regarding others, deferred ruling on the request for an award of statutory damages, and denied the request for an award of costs.The court determined that the prosecutor had provided Mobley with the records-retention schedule and the records created to meet the requirements of former R.C. 309.16(A)(2) for the years 2016 through 2020. However, the court found a genuine question of fact regarding whether the prosecutor provided Mobley with all the records that her office created to meet the requirements of former R.C. 309.16(A)(1) for the years 2016 through 2020. The court thus ordered the prosecutor to provide these records or certify that they do not exist. The court deferred ruling on Mobley’s request for statutory damages until the prosecutor has complied with the limited writ. Mobley’s request for an award of court costs was denied as he had filed an affidavit of indigency. View "State ex rel. Mobley v. Powers" on Justia Law

This case pertains to a public records request made by Marcellus Gilreath to the Ohio Department of Job and Family Services (ODJFS) and its director, Matt Damschroder. Gilreath sought access to specific records related to him, including his case history in the Client Registry Information System Enhanced (CRIS-E), his Ohio Benefits case history, his overpayment records, and records of any investigation into his alleged theft of food stamps.After not receiving a response from ODJFS or Damschroder for several months, Gilreath filed a mandamus action, following which ODJFS provided him with some of the requested records. Gilreath then requested that the court issue a writ of mandamus to compel ODJFS and Damschroder to allow him to inspect the provided documents in their native electronic format, to search for additional records, and to organize and maintain their emails in a manner that they can be made available for inspection. He also sought an award of statutory damages, court costs, and attorney fees.The Supreme Court of Ohio denied Gilreath's request for a writ of mandamus, finding that ODJFS and Damschroder had no obligation to allow him to inspect the records in their native electronic format. The court also found that ODJFS and Damschroder did not possess or control the county emails Gilreath sought, and that his request for these emails was not sufficiently clear. Furthermore, the court determined that Gilreath had not requested ODJFS and Damschroder to organize and maintain their emails in his original complaint.However, the court did grant Gilreath's request for an award of statutory damages, awarding him $1,000 due to the significant delay in ODJFS's response to his public records request. The court denied his requests for court costs and attorney fees. View "State ex rel. Gilreath v. Cuyahoga Job & Family Services" on Justia Law

This case involves an appeal from the Tenth District Court of Appeals of Ohio. The appellant is the State of Ohio, represented by the Attorney General, and the appellees are FirstEnergy Corporation, Samuel Randazzo, and a consulting company controlled by Randazzo. Randazzo, the former chairman of the Public Utilities Commission of Ohio (PUCO), allegedly received a $4.3 million bribe from FirstEnergy Corporation. The state of Ohio filed a civil action against Randazzo and his consulting company to recover the proceeds of the bribe. The state sought attachment orders to prevent Randazzo from draining his bank and brokerage accounts. The trial court granted the state’s motion ex parte, without notice to Randazzo and his attorneys. After learning about the court's decision, Randazzo requested a hearing and moved to vacate the orders. The court held a hearing with both sides present and declined to discharge the orders of attachment. Randazzo appealed to the Tenth District Court of Appeals, which found the orders of attachment had been improperly granted. The Court of Appeals determined that the state had failed to meet its burden at the ex parte hearing to establish the irreparable injury requirement.Upon appeal by the state, the Supreme Court of Ohio reversed the judgment of the Court of Appeals and reinstated the orders of the trial court. The Supreme Court held that the Court of Appeals erred by basing its decision on the ex parte requirements. The Supreme Court ruled that the court of appeals should have reviewed the trial court's denial of the motion to vacate the attachment rather than the irreparable injury requirement for an ex parte order. The Supreme Court concluded that the proper remedy for a party dissatisfied with an ex parte attachment order is to request a hearing on the order at which both parties may be heard. It also concluded that Randazzo failed to demonstrate any prejudice from the use of improper garnishment forms. View "State ex rel. Yost v. FirstEnergy Corp." on Justia Law

In the case before the Supreme Court of Ohio, the issue concerned whether a landlord or landlord's agent can prohibit a person from entering leased premises, even if that person has received permission from a tenant. The case arose when Antonio Randolph was banned from an apartment complex by the property manager and was then later arrested and charged with criminal trespass after he was discovered in his uncle's apartment at the complex, which his uncle had invited him to. The trial court found Randolph guilty of criminal trespass. The Sixth District Court of Appeals reversed the trial court's judgment, holding that the city had to prove that Randolph had entered the premises without privilege, and that his uncle's invitation to the apartment contradicted this.Upon review, the Supreme Court of Ohio agreed with the Sixth District's decision. The court held that a landlord or landlord's agent generally may not exclude a person from rented premises such that the excluded person is considered a trespasser when on the premises even if the person received permission to enter the premises from a tenant of the property. The court noted that Ohio law provides that a landlord cedes his or her possessory interests in leased property to the tenant and therefore may not prohibit the tenant from inviting guests onto the property.However, the court also highlighted that a landlord can maintain control over access to a property if the landlord so desires, provided that this authority is reserved in the lease agreement. In the absence of such a provision in the lease agreement, a tenant may invite onto the property a person whom the landlord has sought to ban from the premises. The judgment of the Sixth District Court of Appeals was affirmed. View "State v. Randolph" on Justia Law

The Supreme Court of Ohio dealt with a case involving the plaintiff, who was acting both individually and as the executor of an estate, and the defendants, which included a medical center and various medical professionals. However, the opinion provides very little information about the specific facts of the case or the legal issues at stake. The Supreme Court of Ohio reversed the judgment of the Sixth District Court of Appeals, relying on the authority of a prior case, Everhart v. Coshocton Cty. Mem. Hosp. The case was then remanded back to the Court of Appeals to consider arguments that it had previously declined to address. The specific nature of these arguments, and the reasons for the Court of Appeals' initial refusal to consider them, are not provided in the opinion. As such, the precise holding of the Supreme Court of Ohio in this case cannot be determined from the available information. View "Davis v. Mercy St. Vincent Med. Ctr." on Justia Law

In this case, an appellant challenged his criminal convictions, arguing that the trial court had erred by failing to hold a competency hearing. The appellant's counsel had requested a competency evaluation prior to the trial, but the appellant refused to be transported to the treatment center for the evaluation. The Supreme Court of Ohio held that while the trial court should have held a competency hearing, the error was harmless because the record, when viewed as a whole, did not demonstrate sufficient indicia of incompetency. The court noted that the appellant had demonstrated understanding of the proceedings and had been able to articulate what his counsel had told him about the proceedings. Therefore, the court affirmed the decision of the lower court, upholding the appellant's convictions. View "State v. Mills" on Justia Law

In this case, the Supreme Court of Ohio reversed the judgment of the First District Court of Appeals. The case involved a dispute between Ewing, in her capacity as executor of an estate and personal representative of the deceased's next of kin and beneficiaries, and UC Health along with other defendants. The court did not provide detailed facts or legal conclusions in its decision. Instead, it simply stated that it was reversing the judgment of the lower court based on the authority of a separate case, Everhart v. Coshocton Cty. Mem. Hosp. Since the court does not elaborate on the details of the case nor the reasons for its decision, the exact holding in this case isn't clear from the opinion provided. View "Ewing v. UC Health" on Justia Law

In this case from the Supreme Court of Ohio, the court considered whether a derivative claim for loss of parental consortium could proceed even when the primary medical negligence claim, on which it was based, was barred by the statute of repose. The appellants, Mr. and Mrs. McCarthy, had filed a medical negligence claim against Dr. Lee and associated medical practices, alleging negligent care in the treatment of Mrs. McCarthy's condition. The claim was dismissed due to the statute of repose. Subsequently, the McCarthys filed a separate claim on behalf of their three minor children for loss of consortium due to the treatment of Mrs. McCarthy's condition. The medical providers moved to dismiss the claim, arguing that it could not stand alone as it was a derivative claim of the previously dismissed medical claim. The trial court granted the motion, and the Court of Appeals affirmed the judgment.Upon appeal, the Supreme Court of Ohio held that the children's derivative claim for loss of parental consortium could not exist when the principal claim on which it was based was extinguished by the statute of repose. The court explained that the statute of repose operates as a substantive bar to a claim, extinguishing both the remedy and the right. Therefore, when a principal claim is extinguished, no other claim derived from it can exist. The court affirmed the lower court's decision to dismiss the children's derivative claim for loss of parental consortium. View "McCarthy v. Lee" on Justia Law

In the case before the Supreme Court of Ohio, the main issue was whether the four-year medical-claims statute of repose, set forth in R.C. 2305.113(C), applies to wrongful-death claims based on medical care. The facts of the case involved Todd Everhart, who had been involved in a car accident in 2003 and was subsequently transferred to Coshocton County Memorial Hospital. Despite finding an abnormality in his chest x-rays, the doctors did not inform him about it. Nearly three years later, Everhart was diagnosed with advanced-stage lung cancer and died two months later. His wife, Machelle Everhart, filed a lawsuit against the hospital and the doctors involved, alleging medical malpractice and wrongful death due to their failure to inform Mr. Everhart of his lung condition.The Supreme Court of Ohio held that the broad definition of "medical claim" clearly and unambiguously includes wrongful-death claims based on medical care. Therefore, the four-year medical-claims statute of repose applies to such claims. The court ruled that the Tenth District Court of Appeals erroneously held otherwise and thus reversed its decision. The court remanded the case to the Tenth District Court of Appeals to address Mrs. Everhart's remaining assignment of error. View "Everhart v. Coshocton Cty. Mem. Hosp." on Justia Law

The Supreme Court of Ohio examined the appropriate standard of review for cases involving a juvenile court’s decision to award permanent custody of a child and to terminate parental rights. The case stemmed from a dispute surrounding the custody of a minor child, Z.C., with the Ashtabula County Children Services Board (ACCSB) granted permanent custody. The father, D.C., appealed this decision, resulting in a conflict between the Eleventh District Court of Appeals and other appellate districts regarding the correct standard of review. The Eleventh District Court of Appeals applied an abuse-of-discretion standard to its review, while other courts applied a sufficiency-of-the-evidence and/or manifest-weight-of-the-evidence standard. The Supreme Court of Ohio held that the correct appellate standards of review in these cases are the sufficiency-of-the-evidence and/or manifest-weight-of-the-evidence standards, depending on the arguments presented by the parties. The Court found that the Eleventh District Court of Appeals erred in applying an abuse-of-discretion standard and remanded the case for review under the correct standard. View "In re Z.C." on Justia Law