Justia Ohio Supreme Court Opinion Summaries

In the case before the Supreme Court of Ohio, Michael Swazey Jr. was indicted for failing to pay child support. He filed a pretrial motion to dismiss the indictment under Rule 12(C)(2) of the Ohio Rules of Criminal Procedure, arguing that the statutes he allegedly violated did not apply to him. The trial court declined to consider Swazey's motion on the merits, holding that the arguments raised were not permitted under Rule 12(C)(2) but should instead be presented at the close of the state’s case at trial. Swazey subsequently pleaded guilty to all counts.On appeal, the Ninth District Court of Appeals held that Swazey’s Rule 12(C)(2) motion was proper and should have been considered on the merits. It also held that by entering a guilty plea, Swazey did not waive his right to raise a constitutional challenge on appeal.The Supreme Court of Ohio affirmed the court of appeals' decision, stating that Swazey's motion to dismiss was appropriate under Rule 12(C)(2), and that his guilty plea did not waive his right to raise his constitutional challenge on appeal. Therefore, the Supreme Court of Ohio remanded the case back to the trial court to consider Swazey's pretrial motion. View "State v. Swazey" on Justia Law

The Supreme Court of Ohio found that the Cedar Point Police Department (CPPD), which provides security, policing, and law-enforcement services at the Cedar Point amusement park, is required to respond to valid public-records requests related to those duties. The court concluded that the CPPD is the functional equivalent of a public institution for purposes of the Public Records Act. The court ordered the CPPD to produce any records responsive to the public-records requests by relators WTOL Television, L.L.C., WKYC-TV, L.L.C., and WBNS-TV, Inc. Although the court awarded court costs to the relators, it denied their requests for statutory damages and attorney fees. The case arose after the relators, who are media companies broadcasting news in Ohio, requested records related to a guest injury at Cedar Point and alleged sexual assaults at Cedar Point employee housing. The CPPD, Cedar Fair, and Ronald E. Gilson (the director of security at Cedar Point and the chief of police of the CPPD) failed to provide the requested records, leading to the relators filing a mandamus action. View "State ex rel. WTOL Television, L.L.C. v. Cedar Fair, L.P." on Justia Law

In 2016, Brian N. Spencer was convicted of possession of heroin and marijuana with a firearm specification, and having a weapon while under disability by a Franklin County Court of Common Pleas jury. On the day of the trial, Spencer requested a new attorney, claiming that his appointed counsel was colluding with the prosecutor. When the court refused, Spencer decided to represent himself, despite warnings about the risks. Following his conviction, Spencer appealed to the Tenth District Court of Appeals, arguing that his right to counsel was violated, but the court affirmed the lower court's ruling.In 2022, Spencer filed a habeas corpus complaint in the Seventh District Court of Appeals, arguing that his convictions and sentence are void because the trial court violated his right to counsel. The court dismissed the complaint and Spencer appealed to the Supreme Court of Ohio.The Supreme Court affirmed the Seventh District's dismissal of the complaint. The Supreme Court held that even if the trial court had violated Spencer’s right to counsel, it did not deprive the court of subject-matter jurisdiction. A violation of the defendant’s right to counsel is a structural error that is reversible on appeal, but it does not result in a sentence that is void for the court’s lack of subject-matter jurisdiction. The court further noted that Spencer had an adequate remedy in the ordinary course of law through direct appeal of his convictions and sentence, which he had already pursued. Thus, his convictions and sentences were not void and he was not entitled to a writ of habeas corpus. View "State ex rel. Spencer v. Forshey" on Justia Law

In the case before the Supreme Court of Ohio, the issue was the quantum of evidence required to satisfy the probable-cause standard for determining whether a juvenile-court offender may be bound over to adult court. The case arose from an incident where a juvenile, E.S., was in a stolen car during a police chase, with his friend E.M., who was driving. After the car crashed, E.M. was found dead from a gunshot wound. A gun was found under the car’s passenger seat where E.S. had been seated, and E.S.'s DNA was found on the trigger and the grip of the gun. A bullet that had been fired from the gun was found in the driver's side front door. E.S. was charged in juvenile court with multiple offenses relating to the stolen car, the gun, and E.M.’s death.The juvenile court found probable cause for some charges but not for involuntary manslaughter or reckless homicide. The state appealed the juvenile court's decision. The Court of Appeals affirmed the juvenile court’s judgment. The state then appealed to the Supreme Court of Ohio.The Supreme Court of Ohio reversed the judgment of the Court of Appeals. The court held that the state had presented sufficient evidence to establish probable cause to believe that E.S. had committed the offense of involuntary manslaughter. The court found that the state’s evidence, both circumstantial and direct, was sufficient to establish probable cause. The court held that the juvenile court and the Court of Appeals had erroneously held the state to a higher burden than required for establishing probable cause in a bindover proceeding. The case was remanded back to the juvenile court for further proceedings. View "In re E.S." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus seeking to compel the Ohio Department of Rehabilitation and Correction and the Bureau of Sentence Computation (collectively, DRC) to calculate his minimum sentence to be fifteen years, holding that the court of appeals did not err.In 1996, Appellant was convicted on three counts of rape, one count of kidnapping, and one count of aggravated robbery. The trial court sentenced him to three life sentences and two sentences of ten to twenty-five years, to be served consecutively. DRC calculated Defendant's sentence to be forty-five years to life. Appellant later brought this mandamus action, arguing that DRC erroneously calculated his minimum sentence by adding three ten-year minimum sentences associated with his life sentence. The court of appeals granted DRC's motion to dismiss. The Supreme Court affirmed, holding that the court of appeals did not err in deciding that DRC correctly calculated Appellant's parole eligibility under Ohio Rev. Code 2967.13(F). View "State ex rel. Stokes v. Dep't of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against Warden Tom Watson of the North Central Correctional Institution, holding that Appellant was not entitled to relief.Appellant was convicted on sixty-one counts of pandering obscenity involving a minor and sentenced to thirty-six and one-half years in prison. Appellant later filed this habeas petition alleging that he was being unlawfully imprisoned. The court of appeals granted the warden's motion to dismiss. The Supreme Court affirmed and denied Appellant's motion for judicial notice, holding that Appellant was not entitled to a writ of habeas corpus because he did not show that his maximum prison sentence had expired or that the trial court lacked jurisdiction to later resentence him. View "State ex rel. King v. Watson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition seeking a writ of prohibition to bar Judge David M. Ondrey of the Geauga County Court of Common Pleas from exercising jurisdiction over a hearing to determine the amount of reasonable attorney fees that Appellant owed based on conduct he committed that the judge found frivolous, holding that there was no error.Appellant sued the Geauga County Republican Central Committee seeking an injunction. Judge Ondrey granted the committee's motion to dismiss. The committee then filed a motion seeking fees it incurred in defending against Appellant's "frivolous" lawsuit. Thereafter, Appellant filed an original action seeking a writ of prohibition to prevent the judge from conducting the hearing on the question of attorney fees. In granting Judge Ondrey's motion to dismiss the court of appeals rejected Appellant's contention that Judge Ondrey exceeded his subject matter jurisdiction by failing strictly to comply with the procedures prescribed by Ohio Rev. Code 2323.51. The Supreme Court affirmed, holding that Judge Ondrey did not patently or unambiguously exceed his jurisdiction. View "State ex rel. Ames v. Ondrey" on Justia Law

In this case addressing the General Assembly districting plan adopted by the Ohio Redistricting Commission in September 2023 the Supreme Court granted motions to dismiss brought by Petitioners, who filed motions for leave to file objections instanter to the plan and denied motions to vacate and for leave to file objections, holding that dismissal was warranted.The Commission adopted a new redistricting plan in September 2023 by a unanimous vote. Petitioners moved for leave to file objections. Respondents, members of the Commission, moved to dismiss the cases and to vacate the court's orders declaring the districting plan adopted by the General Assembly in September 2021 as unconstitutional. The Supreme Court granted the motions to dismiss, denied the motions to vacate as moot, and denied the motions for leave to file objections to the September 2023 plan, holding that now that the Commission has adopted a plan with bipartisan support, the facts before the Court bore no resemblance to the allegations in Petitioners' complaints. View "League of Women Voters of Ohio v. Ohio Redistricting Comm'n" on Justia Law

The Supreme Court declined to accept this discretionary appeal filed on behalf of H.R. and sanctioned the three attorneys representing H.R. for instituting a frivolous appeal.The underlying dispute involved two motions filed by H.R. to modify a divorce decree regarding a spousal support obligation payable by P.J.E. to H.R. The trial court denied H.R.'s motion to continue the hearing on her motions to modify, and the court of appeal dismissed H.R.'s appeal. The Supreme Court dismissed H.R.'s appeal and sanctioned H.R.'s attorneys with paying P.J.E.'s reasonable attorney fees and declaring them to be vexatious litigators, holding that the three attorneys had repeatedly engaged in frivolous conduct. View "H.R. v. P.J.E." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's complaint for a writ of mandamus requiring the Industrial Commission of Ohio to award him a scheduled award of permanent partial disability (PPD) compensation under Ohio Rev. Code 4123.57(B) for the loss of the use of his right hand, holding that the court of appeals correctly denied the writ.Appellant was injured during the course of his employment as a laborer when he fell from a roof onto concrete below. A district hearing officer granted Appellant's request for scheduled-loss compensation, but a staff hearing officer vacated that order on appeal. The court of appeals denied Appellant's ensuing complaint for a writ of mandamus. The Supreme Court affirmed, holding that some evidence supported the commission's decision denying Appellant's request for compensation for the loss of the use of his right hand, and the commission did not abuse its discretion. View "State ex rel. Block v. Industrial Commission of Ohio" on Justia Law