Justia Ohio Supreme Court Opinion Summaries

Appellee was employed by the village of Cardington from 2000 to 2009. When he discovered that someone was discharging a hazardous chemical that was passing through the village’s wastewater treatment plant (WWTP), Appellee voiced his concerns about the WWTP to the village council. Ultimately, Appellee was instrumental in exposing an automotive-parts manufacturer’s criminal discharge of hazardous chemicals into the public water supply. However, a few months after Appellee reported the problems with the WWTP, the village terminated Appellee for reasons disputed by the parties. Appellee sued the village, claiming that he was fired in violation of Ohio’s whistleblower statute. The trial court granted summary judgment for the village. The court of appeals reversed, concluding that a genuine issue of material fact existed as to whether Appellee engaged in whistleblowing under the whistleblower statute. The Supreme Court reversed, holding that Appellee did not satisfy the procedural requirements of the whistleblower statute, and therefore, Appellee did not qualify for whistleblower protection. View "Lee v. Cardington" on Justia Law

Following a jury trial, Defendant was convicted of the aggravated murders of his girlfriend and two children. The trial court sentenced Defendant to death. The Supreme Court affirmed. The Supreme Court affirmed the convictions and sentence of death, holding (1) the prosecutor did not violate Batson v. Kentucky during voir dire; (2) while the prosecutor made improper comments, the improper comments were not prejudicial and did not deny Defendant a fair trial; (3) the trial court did not err in admitting surveillance videos into evidence; (4) the evidence was sufficient to sustain Defendant’s convictions; (5) Defendant’s counsel did not provide ineffective assistance during either phase of trial; and (6) the death penalty was appropriate and proportionate when compared to death sentences approved in similar cases. View "State v. Pickens" on Justia Law

In December 2012, a reporter for the Cincinnati Enquirer requested the court docket showing the cases Hamilton County Juvenile Court Judge Tracie Hunter had presided over during December. The juvenile court administrator sent to the Enquirer the requested documents, but the documents were redacted to provide only the initials of the juveniles. The Enquirer filed this action in mandamus seeking a writ ordering Judge Hunter to reveal the names of the juveniles. The First District Court of Appeals ruled in favor of the Enquirer and ordered Judge Hunter to produce unredacted copies of her docket. In January 2014, the Supreme Court disqualified Judge Hunter from acting as a judge. The Court then dismissed this appeal, as a live controversy no longer existed here because Judge Hunter no longer had power to provide access to the requested records. View "State ex rel. Cincinnati Enquirer v. Hunter" on Justia Law

After a trial, Defendant was convicted of three counts of complicity to commit aggravated murder, two counts of attempted aggravated murder, and related crimes. After a mitigation hearing, the jury recommended death for the three aggravated murders. The trial court sentenced Defendant to death. The Supreme Court affirmed. Defendant filed a petition for postconviction relief, arguing that his trial counsel provided ineffective assistance by failing to conduct an adequate mitigation investigation prior to his mitigation hearing. The trial court denied Defendant’s petition for postconviction relief. The court of appeals vacated Defendant’s death sentence and ordered a new sentencing hearing, concluding that trial counsel’s decision to present only positive mitigation evidence was unreasonable, and undiscovered mitigating evidence might have influenced the jury’s appraisal of Defendant’s culpability. The Supreme Court affirmed, holding (1) trial counsel were deficient by failing to conduct a thorough and adequate investigation into Defendant’s background before his mitigation hearing; and (2) the court of appeals did not err in determining that counsel’s deficiency was prejudicial under Strickland. View "State v. Herring" on Justia Law

Mallon Roberts was found guilty of murder. On appeal, Roberts asserted that certain evidence should not have been allowed in the trial. After the conviction was affirmed, Roberts filed a motion for a new trial on the same basis. The trial court judge, Judge Melba Marsh, overruled the motion. Roberts then filed this action in the court of appeals asking that the court issue a writ of procedendo ordering Judge Marsh to rule on his motion. Specifically, Roberts contended that Judge Marsh’s ruling on his motion was not a proper ruling because it did not include required findings of fact and conclusions of law. The court of appeals dismissed the case. The Supreme Court affirmed, holding that Roberts had an adequate alternative remedy in the ordinary course of law, and because Judge Marsh had in fact ruled on the motion, Roberts was not entitled to a writ of procedendo. View "State ex rel. Roberts v. Marsh" on Justia Law

The two property owners of two different parcels of real property, one of which was situated in the Dublin City School District and the other in the Columbus City School District, filed claims for tax exemption on the basis that Columbus State Community College was a tenant in each of the buildings and provided educational services to students at each location. The tax commissioner denied the applications. The Board of Tax Appeals partially granted exemptions, concluding that the Supreme Court’s decision in Cleveland State Univ. v. Perk permitted exemptions under Ohio Rev. Code 5709.07(A)(4) when the public college leased the property from a landlord. The Supreme Court reversed, holding that the BTA erred by construing section 5709.07(A)(4) to allow exemption, as Perk’s holding did not apply to the facts in this case. View "Equity Dublin Assocs. v. Testa" on Justia Law

The Indian Hill Exempted Village School District Board of Education (BOE) passed a resolution to convert 1.25 inside mills from operating levies to permanent-improvement levies. The conversion had the effect of increasing the effective rate of taxation under the “outside millage,” resulting in the district experiencing a net increase of revenue and the district’s taxpayers experiencing an increased burden. The Hamilton County Budget Commission approved to the conversion of the inside mills. The Board of Tax Appeals affirmed. The Supreme Court reversed, holding that because the BOE did not demonstrate that the revenue derived from the increased effective rate of taxation under the outside mills was necessary to cover operating expenses during the ensuing fiscal year, the BOE did not meet the requirements of Ohio Rev. Code 5705.341. View "Sanborn v. Hamilton County Budget Comm’n" on Justia Law

In 2004, Appellant was found guilty of several offenses. Appellant appealed and filed several other actions based on the judgment. Nearly a decade later, Appellant filed a complaint for writ of mandamus in the court of appeals, arguing that the original sentencing entry was never file-stamped and therefore was not a final, appealable order. Appellant sought to compel the Hamilton County Clerk of Courts to file-stamp the original sentencing entry. The court of appeals dismissed the action. The Supreme Court affirmed, holding that Appellant failed to show that the 2004 entry was not file-stamped and was not a final, appealable order. View "State ex rel. Smith v. Winkler" on Justia Law

Ohio Rev. Code 2929.20 provides that a prisoner cannot apply for judicial release until a period of time after the expiration of all mandatory prison terms in the stated prison sentence. Shawn Ware pleaded guilty to two counts of trafficking in crack cocaine. One count was a second-degree felony. Ware’s second-degree felony carried a mandatory prison term. The trial court imposed a four-year prison term for that offense. Ware later sought judicial release, arguing that he was eligible for release before the expiration of his four-year term because the original sentencing entry imposed only a minimum mandatory sentence of two years. The trial court granted the motion, explaining that it had not intended to make all four years of Ware’s sentence mandatory. The Supreme Court reversed, holding that Ware was not eligible for judicial release because his entire sentence was mandatory, and the trial court could not impose a different sentence under Ohio law. View "State v. Ware" on Justia Law

Cqualin Hawkins pleaded guilty to burglary, domestic violence, and assault. Hawkins was sentenced to four years on the burglary charge. Hawkins was later released on community control. While on community control, Hawkins was sentenced to three years for committing a new domestic violence offense. Because of the new crime, Hawkins’s community control release was evoked and his original sentence was reimposed. Hawkins filed this petition for writs of mandamus and habeas corpus asserting that the Ohio Department of Rehabilitation and Correction miscalculated his jail-time credit. The Supreme Court dismissed Hawkins’s habeas petition because it was moot, as Hawkins was no longer in custody at the time of this opinion, and dismissed Hawkins’s complaint for writ of mandamus because of flaws in the complaint. View "State ex rel. Hawkins v. Haas" on Justia Law