Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals dismissing Petitioner's mandamus action after recognizing his status as a vexatious litigator as declared in an earlier, separate matter, holding that Petitioner did not "continue" his proceeding as a vexatious litigator in this case.Appellant filed a mandamus action against the Franklin County Board of Commissioners and mailed his objections to a magistrate's decision to the court of appeals. The court in a separate matter subsequently declared Appellant to be a vexatious litigator. Upon filing Appellant's objections in this case, the court of appeals recognized Appellant's status as a vexatious litigator and sua sponte dismissed the case. The Supreme Court reversed, holding (1) when Appellant mailed his objections and filed his motion for leave, he did not "continue" the proceeding as a vexatious litigator under Ohio Rev. Code 2323.52; and (2) therefore, the court of appeals' dismissal was incorrect. View "State ex rel. Mobley v. Franklin County Bd. of Commissioners" on Justia Law

The Supreme Court dismissed Relator Mark Repp's quo warranto claim he sought to oust Rhonda Best from judicial office and to declare him the rightful holder of the office and dismissed all other claims sua sponte, holding that Repp was not entitled to relief.In 2019, Repp was elected to a six-year term as judge of a municipal court. Less than two years into his term, the Supreme Court found that Repp had engaged in professional misconduct and suspended him for one year from the practice of law. Because Repp failed to perform his official duties for more than six months, the judicial office he held was declared vacant, and Governor Mike DeWine appointed Best to fill the vacancy. After Repp was reinstated to the practice of law he filed this original action seeking a writ of quo warranto to oust Best from officer and also sought a writ of prohibition, declaratory judgment, and injunctive relief. The Supreme Court denied all forms of relief, holding (1) if a judge is absent from his official duties for at least six months, the appropriate legislative authority is allow to declare the judicial office vacant under Ohio Rev. Code 1901.10(B); and (2) Repp's remaining requests either failed to state a claim, or this Court lacked jurisdiction over his claims. View "State ex rel. Repp v. Best" on Justia Law

The Supreme Court denied relief in this expedited election action brought by Brandon King, mayor of East Cleveland, seeking extraordinary writs to compel the removal of a proposed East Cleveland city-charter amendment from the November 7, 2023 general election ballot and to prevent the December 5, 2023 special mayoral-recall election, holding that King was not entitled to relief.On August 9, 2023, the East Cleveland City Council passed resolution submitting to city electors a proposed revision to the city charter that would change the mayoral election from a partisan to a nonpartisan contest. The Cuyahoga County Board of Elections and its individual members (collectively, the board) voted unanimously to approve the proposed city-charter amendment for placement on the November 7 ballot as Issue 48. A city resident later submitted a petition for King's recall as mayor, and the board scheduled a December 5, 2023 special election. King submitted a written protest challenging the placement of Issue 48 on the general election ballot and placement of the mayoral-recall issue on the December 5 special-election ballot. The protest was dismissed. King subsequently filed this action seeking extraordinary relief. The Supreme Court denied relief, holding that the board did not abuse its discretion or disregard applicable law in dismissing King's protest. View "State ex rel. King v. Cuyahoga County Bd. of Elections" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals in this dispute arising out of environmental-cleanup and remediation work at two Superfund sites in Bronson, Michigan, holding that Restatement (Second) 193 does not govern the choice-of-law analysis for bad faith claims.Scott Fetzer Company filed this action asserting a breach of contract claim against certain insurance companies, including Travelers Casualty and Surety Company, alleging breaches of certain insurance contracts. Fetzer also asserted a tort claim against each company, arguing that they had acted in bad faith when handling his claims. As to Travelers, an administrative judge concluded that Ohio law applied to a discovery dispute concerning Scott Fetzer's bad faith claim. The court of appeals affirmed, determining that Ohio law governed the bad-faith discovery dispute because the cause of action was a tort. In affirming, the court applied the choice-of-law rules set forth in section 145 of the Restatement. Travelers appealed, arguing that section 193 governs the choice-of-law analysis for bad faith claims because they arise out of insurance contracts. The Supreme Court affirmed, holding that the court of appeals correctly ruled that the choice-of-law analysis applicable to a bad-faith claim as provided by section 145. View "Scott Fetzer Co. v. American Home Assurance Co." on Justia Law

The Supreme Court granted a writ of prohibition in this original action, holding that the trial court in this case lost jurisdiction to proceed on a request for attorney fees after entering final judgment.After a limited remand in this case stemming from a real estate dispute the trial court entered final judgment, and the judgment was subsequently paid. Thereafter, the prevailing parties filed a motion seeking more than $167,000 in additional attorney fees. Petitioner filed this original action seeking a writ of prohibition alleging that the common pleas court patently and unambiguously lacked jurisdiction to conduct further proceedings. The Supreme Court granted the petition, holding that the court of appeals' mandate did not give the trial court jurisdiction to entertain an attorney fees request that accrued after the final judgment. View "State ex rel. Mather v. Oda" on Justia Law

The Supreme Court affirmed the opinion of the court of appeals rejecting Charles Simpson's peremptory prohibition claim and mandamus claim, holding that the court of appeals did not err in denying the prohibition claim and that Simpson failed to state a valid claim for mandamus relief.Grande Voiture in a separate case filed a motion for an order finding Simpson, the defendant in that case, in contempt of the trial court's order granting declaratory and injunctive relief in favor of Grande Voiture. Common Pleas Court Judge Kimberly Melnick granted Grande Voiture's motion to strike Simpson's answer and counterclaim on the grounds that Grande Voiture's contempt motion was not a pleading. Simpson then filed an original action seeking a peremptory writ of prohibition forbidding the judge from proceeding with the contempt hearing without allowing a jury trial and without considering the answer and counterclaim. Simpson also requested a writ of mandamus compelling the judge to proceed by jury trial on the issues before her. The court of appeals granted the judge's motion to dismiss. The Supreme Court affirmed, holding that Simpson failed to state a valid claim for the writs. View "State ex rel. Simpson v. Melnick" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing two complaints Appellant filed seeking writs of mandamus and prohibition, holding that Appellant was not entitled to writs of mandamus or prohibition vacating his convictions and sentence.Appellant filed both a complaint for a writ of mandamus seeking to compel the trial court to vacate his criminal convictions and sentence and a complaint for a writ of prohibition against the trial court raising the same underlying issues. The court of appeals denied the writs, holding (1) Appellant had an adequate remedy in the ordinary course of the law through direct appeal to challenge any violation of his right to counsel; and (2) Appellant was not entitled to a writ requiring the trial court to review issues related to the withdrawal of his counsel on direct appeal. View "State ex rel. Boyd v. Tone" on Justia Law

The Supreme Court vacated its decision in State v. Gwynne, __ N.E.3d __ (Ohio 2022) (Gwynne IV) and affirmed the judgment of the Fifth District Court of Appeals in this sentencing dispute, holding that the court of appeals properly applied the plain language of Ohio Rev. Code 2953.08(G)(2) in concluding that the record supported the trial court's consecutive sentence findings.Appellant pleaded guilty to seventeen counts of second-degree burglary, among other offenses. The trial court made the findings required under Ohio Rev. Code 2929.14(C)(4) for imposing consecutive sentences and ordered the felony sentences to be served consecutively, for an aggregate sentence of sixty-five years. The appellate court affirmed. The Supreme Court reversed in Gwynne IV, holding on de novo review that the findings required by section 2929.14(C)(4) to impose consecutive prison sentences on an offender must be made in consideration of the aggregate term. The Supreme Court then granted the State's motion for reconsideration, vacated its decision in Gwynne IV and affirmed the court of appeals, holding (1) Ohio Rev. Code 2953.08(G)(2) requires an appellate court to defer to a trial court's consecutive sentence findings, and those findings must be upheld unless they are clearly and convincingly not supported by the record; and (2) the appellate court properly applied that standard. View "State v. Gwynne" on Justia Law

The Supreme Court denied mandamus relief in this action brought under Ohio's Public Records Act, Ohio Rev. Code 149.43, by Kevin Payne against Kelly Rose, an inspector at the Richland Correctional Institution (RCI), holding that Payne did not have a cognizable claim in mandamus.Payne, an inmate at RCI, sent a public-records request to Rose for a copy of, among other things, JPay support ticket number MACI 1220002928. Rose responded that she obtained the requested record and provided a copy of it to Payne. Payne brought this action seeking a writ of mandamus ordering Rose to produce the requested record and statutory damages. The Supreme Court denied mandamus relief, holding (1) because Payne received his requested record before instituting this action he never had a cognizable claim in mandamus; and (2) statutory damages did not accrue. View "State ex rel. Payne v. Rose" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's conviction for violating Ohio Rev. Code 2907.06(A)(2), holding that a jury can reasonably infer that a defendant knew a victim to be substantially impaired so as to convict him of sexual imposition under the statute.Defendant was charged with violating Ohio Rev. Code 2907.06(A)(1) and (2) for his sexual contact with woman who was blind and suffered from unspecified developmental disabilities. The jury found Defendant guilty of both counts of sexual imposition. The court of appeals reversed Defendant's conviction for violating section 2907.06(A)(2), concluding that the victim was not substantially impaired. The Supreme Court reversed, holding (1) knowledge of a victim's "substantial impairment" can be proved both by the defendant's knowledge of the victim's blindness and evidence of the nature of the interactions between the defendant and the developmentally disabled victim; and (2) there was sufficient evidence to find that Defendant knew that the victim's blindness, together with her developmental disabilities, substantially impaired her ability to appraise the nature of and control of Defendant's conduct. View "State v. Jordan" on Justia Law