Justia Ohio Supreme Court Opinion Summaries

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

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