Justia Ohio Supreme Court Opinion Summaries

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

Claimant was injured when he fell while trying to cut a tree branch. Claimant filed an application for workers’ compensation benefits alleging that the injury had occurred while he was an employee of Appellee. The Bureau of Workers’ Compensation allowed the claim. Appellee purportedly appealed from the order of the Bureau, claiming that Claimant was not his employee at the time of the accident. The Commission concluded that Appellee’s appeal substantially complied with the statutory requirements for an administrative notice of appeal, accepted the appeal as valid, and referred the matter to a district hearing officer. A hearing officer disallowed the claim on the merits, concluding that Claimant was not an employee of Appellee. The Commission affirmed. Claimant filed a complaint for writ of mandamus alleging that the Commission abused its discretion in determining that Appellee’s administrative appeal was valid. The court of appeals denied the writ. The Supreme Court affirmed, holding that because Claimant had an adequate remedy at law by way of an appeal under Ohio Rev. Code 4123.512 regarding the issues he raised in this case, he was not entitled to relief in mandamus. View "State ex rel. Alhamarshah v. Indus. Comm’n" on Justia Law

Claimant was injured at work and later applied for permanent-total-disability benefits. The Industrial Commission denied the application. Claimant later filed a second application supported a letter from his treating physician, Dr. Karl Metz. The Commission also submitted a report from Dr. Steven Van Auken. A staff hearing officer denied permanent total disability based on the two reports. Claimant filed a complaint for a writ of mandamus alleging that the Commission abused its discretion because it failed to consider additional restrictions placed on him in the two reports. A magistrate concluded that the Commission did not abuse its discretion by relying on the reports of Drs. Metz and Van Auken. The court of appeals adopted the magistrate’s conclusions of law regarding Van Auken’s opinion but issued a limited writ of mandamus ordering the Commission to clarify Dr. Metz’s opinion or to obtain additional medical evidence. The Supreme Court reversed, holding that the court of appeals abused its discretion in granting the limited writ because its decision was based on speculation that there was a possible conflict in Dr. Metz’s report that could be construed to bar sedentary employment, which did not, by itself, justify the issuance of a limited writ. View "State ex rel. Metz v. GTC, Inc." on Justia Law

Sophia Stevens slipped and fell at work in 1979. Thirty years later, Stevens filed a motion for permanent-total-disability compensation. Through a staff hearing officer, the Industrial Commission initially granted benefits, but the full Commission later reconsidered the staff hearing officer’s order and denied Stevens’s request. Stevens filed a complaint for a writ of mandamus alleging that the Commission abused its discretion when it exercised continuing jurisdiction and denied compensation. The court of appeals (1) concluded that Stevens had not met her burden of proof for mandamus relief on the question of continuing jurisdiction, but (2) determined that Stevens was deprived of due process when one of the three voting commissioners did not attend the hearing. Thus the court issued a writ of mandamus ordering the commission to conduct another hearing with all three commissioners present. The Supreme Court reversed and denied the writ, holding (1) Stevens I properly focused on Stevens’s burden of proof for mandamus relief; (2) this Court’s decision in State ex rel. Sigler v. Lubrizol Corp. requires reversal of the judgment in Stevens II; and (3) the Commission’s order denying permanent-total-disability benefits is supported by the evidence. View "State ex rel. Stevens v. Indus. Comm’n" on Justia Law

Appellant, an inmate at Lorain Correctional Institution, sent Appellee, the warden of the institution, a public-records request to copy and inspect the Ohio Department of Rehabilitation and Correction employee rules of conduct. Appellant asserted that the requests were ignored. Appellant subsequently petitioned the court of appeals for a writ of mandamus against Appellee. The court of appeals dismissed the claim, finding that Appellant had failed to comply with Ohio Rev. Code 2969.25(C). Appellant filed a Ohio R. Civ. P. 60(B) motion seeking leave to amend his complaint, which the court also denied. The Supreme Court affirmed, holding that the court of appeals did not err in (1) dismissing the complaint due to Appellant’s failure to comply with section 2969.25; and (2) denying Appellant’s Rule 60(B) motion, as the failure to comply with the mandatory requirements of section 2969.25(C) is not curable by subsequent amendment. View "State ex rel. Young v. Clipper" on Justia Law

Based on investigations by law enforcement officials, a grand jury returned an indictment against several individuals and companies alleging that they had used an Internet gambling system to conceal illegal gambling by presenting it as an Internet sweepstakes. The prosecuting attorney then mailed letters to Plaintiff and other proprietors of Internet sweepstakes cafes threatening criminal prosecution if they did not immediately cease to run the sweepstakes. Plaintiff filed this action seeking to prohibit the prosecuting attorney from enforcing gambling laws against it with respect to Internet sweepstakes. Plaintiff sought to compel discovery of information related to the ongoing criminal investigation. The trial court ordered the prosecuting attorney to produce the information. The prosecuting attorney filed an interlocutory appeal. The court of appeals balanced the competing interests of Plaintiff and the prosecuting attorney and affirmed in part and reversed in part, holding that certain information being sought was not protected by the law enforcement investigatory privilege. The Supreme Court affirmed, holding (1) the law enforcement investigatory privilege is not absolute; and (2) the balancing test the Court adopted in Henneman v. Toledo for weighing the interests of law enforcement in keeping the information confidential against the needs of a civil litigant who requests the information in discovery remains valid. View "J & C Marketing, LLC v. McGinty" on Justia Law

Appellee filed a workers’ compensation claim from a work-related injury that occurred in 2007 while he was employed as a bricklayer for Appellant. Appellee had three other workers’ compensation claims from work-related injuries that occurred in 1992 and 2005. His claim was allowed. Appellee later applied for permanent-total-disability compensation. Appellee’s treating physician and a psychologist opined that Appellee was incapable of working due to his psychological condition caused by the 2007 injury. A staff hearing officer with the Industrial Commission granted Appellee’s application and ordered permanent total disability compensation. The hearing officer apportioned the cost of the award entirely to the 2007 claim. Appellant filed a complaint for a writ of mandamus. The court of appeals denied the writ, holding that Commission did not err by allocating the entire award to the 2007 claim. The Supreme Court affirmed, holding that the Commission did not abuse its discretion when it attributed the entire award to the 2007 claim. View "State ex rel. Turner Constr. Co. v. Indus. Comm’n" on Justia Law

Appellant was injured during the scope of his employment. In 2010, the Industrial Commission of Ohio found that Appellant had a six percent permanent partial disability and granted him compensation accordingly. In 2010, the Commission increased the award by four percent for a total of ten percent permanent partial disability. In 2011, the Commission again amended Appellant’s claim to include an additional condition and increased the award by an additional four percent. Appellant filed a complaint in mandamus alleging that the Commission’s order awarding only a four percent increase was not supported by the evidence. The court of appeals denied the writ. The Supreme Court affirmed, holding that the Commission did not abuse its discretion in adopting a percentage of disability that fell within the range suggested by two doctors. View "State ex rel. Romero v. River City Drywall Supply, Inc." on Justia Law

In 2004 and 2007, two fires broke out in two separate buildings of the Village Green Apartments. Plaintiffs, tenants of the apartment complex, filed suit against the apartment complex’s landlords, claiming that the buildings had been negligently constructed. The landlords were found liable. The jury awarded compensatory damages of $582,146, punitive damages of $2,000,000, and attorney fees of $1,040,000. The court of appeals affirmed. The Supreme court affirmed with respect to all issues except the award of punitive damages, holding (1) the amount of punitive damages exceeded the limit prescribed by Ohio Rev. Code 2315.21(D)(2)(a); (2) the trial court did not abuse its discretion in allowing the issue of punitive damages to go to the jury; and (3) the trial court did not abuse its discretion in allowing the jury to determine that the landlords had failed to comply with Ohio Rev. Code 5321.04 for failure to correct defects occurring in electrical wiring. View "Sivit v. Village Green of Beachwood, L.P." on Justia Law