Justia Ohio Supreme Court Opinion Summaries

WTS Acquisition Corporation purchased Ameritemps, Inc. and then transferred the assets to its wholly owned subsidiary, RFFG, LLC. RFFG continued operating the business under the Ameritemps name. The Ohio Bureau of Workers’ Compensation notified RFFG that it had determined that RFFG was a successor employer for workers’ compensation purposes and that it intended to calculate RFFG’s workers’ compensation premium rate based on Ameritemps’ experience rating. RFFG filed a complaint for a writ of mandamus alleging that the Bureau had abused its discretion when it determined RFFG to be the successor in interest to Ameritemps. The court of appeals denied the writ. The Supreme Court affirmed, holding that the court of appeals did not err in concluding that the decision of the Bureau was supported by the evidence and was not an abuse of discretion. View "State ex rel. RFFG, LLC v. Ohio Bureau of Workers' Comp." on Justia Law

Defendant was convicted of two counts of rape of his minor stepdaughter. The Supreme Court reversed and remanded to the court of appeals to consider whether the trial court abused its discretion in admitting other-acts evidence under Ohio R. Evid. 404(B) during trial. On remand, the court of appeals vacated Defendant’s conviction and ordered a new trial, concluding that the trial court abused its discretion in admitting the other-acts evidence. The Supreme Court affirmed, holding (1) in determining the erroneous admission of evidence under Rule 404(B) is harmless error, an appellate court must consider both the impact of the offending evidence on the verdict and the strength of the remaining evidence after the tainted evidence is removed from the record; and (2) the court of appeals in this case did not err in finding that the Rule 404(B) evidence was improperly admitted at trial and in granting a new trial. View "State v. Morris" on Justia Law

Canal Winchester MOB, LLC (“MOB”), the ground lessee of a medical office building, filed a complaint challenging the tax-year-2010 valuation of the building. The Board of Revision retained the auditor’s valuation. MOB, together with the record owner of the property, appealed. In its decision, the Board of Tax Appeals (“BTA”) sua sponte considered the jurisdictional validity of the complaint and held that MOB did not have standing to file the complaint. Accordingly, the BTA ordered dismissal. The Supreme Court vacated the BTA’s decision, holding that the BTA should have afforded MOB the opportunity to plead and prove its standing. Remanded. View "Diley Ridge Med. Ctr. v. Fairfield County Bd. of Revision" on Justia Law

In 2008, A police detective placed a global-positioning-system (GPS) tracking device on Defendant’s vehicle without obtaining a search warrant. Based on information gathered using the GPS device, law enforcement officers indicted Defendant for drug-related charges. Defendant moved to suppress the evidence, arguing that the warrantless placement and monitoring of the GPS tracking device on his vehicle violated his Fourth Amendment rights. The trial court denied the motion to suppress. The Supreme Court remanded to the trial court for application of United States v. Jones, decided in 2012, which held that attaching a GPS tracking device to an individual’s vehicle is a search within the meaning of the Fourth Amendment. On remand, the trial court found that placing the GPS device on Defendant’s van violated the Fourth Amendment but that the good-faith exception to the exclusionary rule applied. The Supreme Court affirmed, holding because binding appellate precedent justified placing GPS tracking devices on suspects’ vehicles without obtaining a search warrant at the time of the facts giving rise to this case, the good-faith exception to the exclusionary rule applied and exclusion of the evidence obtained by police in this case was not warranted. View "State v. Johnson" on Justia Law

In 2008, Michael Slager was sentenced for two separate offenses. In 2012 and 2013, Slager filed two complaints for a writ of mandamus in the court of appeals, arguing that he was entitled to additional jail-time credit. Slager subsequently filed motions to voluntarily dismiss and withdraw the actions, which the court of appeals granted. Later in 2013, Slager filed the present case in the Supreme Court seeking a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction and the Bureau of Sentence Computation to grant him additional jail-time credit. The Supreme Court dismissed the cause, holding that Slager’s dismissal in his second case operated as an adjudication upon the merits of his claim to extra jail-time credit and was thus res judicata. View "State ex rel. Slager v. Ohio Dep't of Rehab. & Corr." on Justia Law

After a jury trial, Appellant was convicted of attempted felony murder, felonious assault, and possessing a firearm while under a disability. At issue on appeal was whether a defendant can be convicted of attempted felony murder when there was no resultant death. The court of appeals reversed the conviction for attempted felony murder, concluding that attempted felony murder is not a viable criminal offense under Ohio law. The Supreme Court affirmed, holding that the court of appeals correctly determined that a person cannot be guilty of attempting to purposely or knowingly cause an unintended death, and therefore, attempted felony murder is not a cognizable crime in Ohio. View "State v. Nolan" on Justia Law

Appellants, Cleveland Clinic Foundation and Fairview Hospital, sought approval to build a helipad on the roof of a new two-story addition on the Hospital. The Cleveland Board of Zoning Appeals (BZA) denied a permit to construct the helipad, determining that the Cleveland zoning ordinances did not permit the building of the helipad. The Cuyahoga County Court of Common Pleas reversed, concluding that the helipad was permissible under the ordinances. The court of appeals reversed. The Supreme Court reversed, holding (1) the court of appeals applied an incorrect standard of review in reversing the trial court; and (2) the trial court correctly found that under the current version of the Cleveland zoning ordinances, a helipad was a permitted accessory use for the Hospital. View "Cleveland Clinic Found. v. Bd. of Zoning Appeals" on Justia Law

In 1998, Appellant was found guilty of two counts of aggravated murder and other offenses. Postrelease control was not specifically imposed at the sentencing hearing or in the sentencing entry. Appellant’s convictions were affirmed on appeal. In 2011, Appellant filed a complaint for a writ of procedendo asking the court of appeals to compel the trial judge to resentence him based on the improper imposition of postrelease control at sentencing. The court of appeals dismissed the complaint, concluding that Appellant had an adequate remedy by way of appeal to raise the postrelease-control issue. Nevertheless, the trial court subsequently imposed postrelease control for two of Defendant’s convictions. The court of appeals reversed and remanded. On remand, the trial court vacated the order imposing postrelease control. In 2013, Appellant filed a second complaint for a writ of procedendo arguing that his original sentencing entry was void because postrelease control had not been imposed. The court of appeals denied the petition. The Supreme Court, holding that the petition for a writ of procedendo was barred by res judicata, the case was moot, and Appellant’s arguments were wrong on the merits. View "State ex rel. Gregley v. Friedman" on Justia Law

Defendant was arrested pursuant to three misdemeanor arrest warrants. Based on information collected upon the execution of the arrest warrants, Defendant was charged with aggravated murder and aggravated robbery. Defendant filed a motion to suppress all evidence collected as a result of his arrest, contending that the arresting officers lacked a valid warrant to arrest him because no probable-cause determination was made before the warrants were issued and because the criminal complaints on which the warrants were based contained no information that would support a finding of probable cause. The trial court denied the motion to suppress, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the lower courts correctly determined that the warrants were issued improperly because there was no determination of probable cause; and (2) the remedy of suppression of the evidence obtained pursuant to the defective warrants was not available because the officers relied in good faith upon a procedure established in binding precedent. View "State v. Hoffman" on Justia Law

After a jury trial, Appellee was convicted of, inter alia, engaging in a pattern of corrupt activity. Appellee’s convictions were affirmed on appeal. The court of appeals reversed the conviction for engaging in a pattern of corrupt activity, concluding that Appellee’s appellate counsel had been ineffective for failing to challenge the jury instructions defining the term “enterprise,” as the jury instructions had been inadequate. The Supreme Court reversed, holding that the jury instructions, when read and understood together, adequately conveyed the law regarding the term “enterprise” and that the jury was appropriately and adequately informed on the issue. View "State v. Griffin" on Justia Law