Justia Ohio Supreme Court Opinion Summaries

After a jury trial, Defendant was found guilty of two counts of retaliation, criminal damaging, vandalism, criminal trespass, possessing criminal tools, and ten counts of pandering. Defendant appealed, arguing that the trial court erred in denying his motion to suppress information found on his computer. The court of appeals affirmed, concluding that the affidavit provided a substantial basis for concluding that evidence of criminal activity would be found there. The Supreme court reversed, holding (1) the search warrant was not supported not supported by probable cause, and (2) the search warrant violated the Fourth Amendment requirement of particularity, thereby rendering invalid the search of Defendant’s computer. View "State v. Castagnola" on Justia Law

In 1979, Appellant was charged in juvenile court in five cases. In each case, the juvenile court held a bindover hearing and transferred the case to the common pleas court. Appellant was convicted in three of the five cases. In 2013, Appellant filed a complaint for a writ of procedendo and/or mandamus in the court of appeals, asserting that the bindovers were invalid because they had not been signed by a judge or journalized by the court’s clerk. The court of appeals denied the writ. The Supreme Court affirmed, holding that because Appellant had adequate remedies at law in three cases, the issue was res judicata as to four cases, and no meaningful relief was available in the fifth case. View "State ex rel. McCuller v. Cuyahoga County Court of Common Pleas" on Justia Law

In 1975, Appellant was convicted of premeditated murder and felony murder and was sentenced to two terms of life imprisonment. Appellant’s conviction and sentence were affirmed on appeal. Appellant filed various postconviction motions and petitions without success. In 2014, Appellant filed a petition for a writ of mandamus, arguing that the courts should have conducted a merger analysis and sentenced him for only one crime. The court of appeals dismissed the petition for mandamus. The Supreme Court affirmed, holding that Appellant’s claim was res judicata because the final judgments in Appellant’s previous motions and appeals were conclusive as to Appellant’s claims. View "State ex rel. Robinson v. Huron County Court of Common Pleas" on Justia Law

In 2009, Defendant pled guilty to burglary. The trial judge sentenced Defendant to five years of community control and warned him that a violation of community control would result in an eight-year prison sentence. In 2011, the judge found Defendant in violation of the terms of community control and ordered the sentence into execution. The next day, the judge issued a nunc pro tunc entry clarifying her intent to sentence Defendant to prison for eight years. Defendant later filed this action for a writ of mandamus, claiming he was entitled to a writ to compel the trial judge to place him on community control or repentance him because the nunc pro tunc sentencing order was invalid. The Supreme Court affirmed, holding that Defendant failed to demonstrate a legal right to a writ of mandamus. View "State ex rel. Davis v. Saffold" on Justia Law

In 1992, while he was still a minor, Appellant was adjudicated delinquent for committing the equivalent of an operating a motor vehicle while intoxicated (OVI) offense. Appellant was not represented by counsel during the adjudication. In 2011, Appellant was convicted of OVI offenses that became felonies under the enhancing provision of Ohio Rev. Code 4511.19(G)(1)(d). The State added Appellant’s juvenile OVI adjudication to his four prior adult convictions to reach the “five or more” offenses threshold required to enhance his sentence under section 4511.19(G)(1)(d). Appellant moved to suppress the evidence of his juvenile adjudication, arguing that the adjudication violated his constitutional right to counsel. The trial court overruled the motion to suppress. Appellant was subsequently convicted of two counts and used Appellant’s 1992 juvenile adjudication as an OVI enhancement tool. The Supreme Court reversed and remanded for resentencing, holding that an adjudication of delinquency may not be used to enhance the penalty for a later offense under section 4511.19(G)(1)(d) when the adjudication carried the possibility of confinement, the adjudication was uncounseled, and there was no effective waiver of the right to counsel. View "State v. Bode" on Justia Law

In 2010, Bank filed a foreclosure action against Defendants for allegedly defaulting on a promissory note. The trial court granted Bank’s motion for summary judgment and issued a decree of foreclosure in Bank’s favor. Defendants appealed, asserting four assignments of error, none of which challenged the court’s conclusion that Bank had standing to bring the foreclosure suit. Rather than considering Defendants’ assignments of error, the court of appeals sua sponte considered the issue of standing and held that Bank lacked standing to bring this foreclosure action. The Supreme Court reversed, holding that Bank had standing to file the foreclosure action against Defendants at the time that it filed the complaint in 2010. Remanded. View "Wells Fargo Bank, N.A. v. Horn" on Justia Law

After a jury trial in 1983, Appellant was found guilty of aggravated murder, aggravated burglary, and other offenses. Appellant’s convictions and sentences were affirmed on direct appeal. In 2013, Appellant filed an original action in the court of appeals seeking a writ of mandamus compelling the State to repentance him, arguing that the Supreme Court’s decision in State v. Johnson entitled him to a do novo resentencing. The court of appeals dismissed the petition, concluding that Johnson does not apply retroactively and that claims of sentencing errors are not cognizable in extraordinary writ actions. The Supreme Court affirmed, holding that Appellant was not entitled to a writ of mandamus, as (1) Johnson does not apply retroactively; and (2) Appellant had adequate remedies in the ordinary course of law. View "State ex rel. Walker v. State" on Justia Law

Plaintiff sued Defendants, alleging that he suffered from spinal injuries as a result of Defendants’ medical malpractice. During discovery, Plaintiff requested a recorded surveillance video that Defendants had created of him. Defendants refused to turn over the video, claiming that it was attorney work product that they intended to use only as impeachment evidence. The court of common pleas ordered Defendants to produce the tape. The court of appeals affirmed the trial court’s order, concluding that the discovery order was final and appealable. The Supreme Court vacated the judgment of the court of appeals, holding that Defendants failed to establish that the trial court’s discovery order was a final, appealable order, and therefore, neither this Court nor the court of appeals had jurisdiction to consider the merits of the interlocutory order. View "Smith v. Chen" on Justia Law

After a jury trial, Defendant was convicted of sixty-eight counts, all stemming from Defendant’s business enterprises. As relevant to this case, the jury found Defendant guilty of engaging in a pattern of corrupt activity in violation of Ohio’s Racketeer Influenced and Corrupt Organizations (RICO) statute. Relying on Ohio Rev. Code.14(D)(3)(a), the trial court sentenced Defendant to a mandatory term of ten years on the RICO count. The court of appeals vacated the mandatory ten-year prison term imposed for the RICO count, declaring that section 2929.14(D)(3)(a) was ambiguous. The Supreme Court reversed in part, holding that section 2929.14(D)(3)(a) unambiguously applied to Defendant and that Defendant fell squarely within the scope of section 2929.14(D)(3)(a). After the U.S. Supreme Court decided Alleyne v. United States, Defendant petitioned for certiorari, arguing that Alleyne prohibited imposition of the mandatory ten-year prison term. The U.S. Supreme Court vacated the Ohio Supreme Court’s decision and remanded. The Supreme Court reinstated its prior judgment, holding that imposition of Ohio Rev. Code 2929.14(D)(3)(a)’s mandatory sentence did not offend Defendant’s constitutional rights under Alleyne, as imposition of the mandatory sentence occurred without any judicial fact-finding. View "State v. Willan" on Justia Law

After a jury trial, Appellant was convicted of sixteen criminal counts and sentenced to life in prison. The court of appeals affirmed. Several years later, Appellant filed a complaint for a writ of habeas corpus against Appellee, warden of the Southeastern Correctional Complex, alleging that his convictions were the result of prosecutorial misconduct and that the court that convicted him lacked jurisdiction over him because the statute of limitations had run when he was tried. The court of appeals dismissed the complaint because Appellant had an adequate remedy by way of appeal and because he had failed to comply with Ohio Rev. Code 2969.25(C)(1). The Supreme Court affirmed, as Appellant had alternate remedies at law, which precluded a writ of habeas corpus, and because Appellant failed to comply with section 2969.25(C)(1). View "Russell v. Duffey" on Justia Law