Justia Ohio Supreme Court Opinion Summaries

After a jury trial, Appellant was sentenced to death for the aggravated murder of a police officer. The Supreme Court affirmed Appellant’s convictions and sentence of death, holding (1) the trial court did not err by overruling Appellant’s objection to the State’s peremptory challenge, and the court conducted an adequate voir dire; (2) the trial court did not err by denying Appellant’s motion for a change of venue; (3) the trial court did not commit prejudicial error in its evidentiary rulings or in its instructions to the jury; (4) any questionable conduct that the prosecutor engaged in during the proceedings did not deprive Appellant of a fair trial; (5) Appellant’s counsel provided constitutionally effective assistance; and (6) Appellant’s challenges to the death penalty failed, and the death sentence was appropriate and proportionate in this case. View "State v. Thompson" on Justia Law

This case involved the tax-year-2009 value of a parcel of property and presented the question of whether an auction sale price can ever be regarded as evidence of a property’s value and, if so, under what circumstances. The Board of Tax Appeals (BTA) found that the auction sale in this case was a voluntary, arm’s-length transaction, and therefore, that the sale price was the best evidence of the true value of the property. The Supreme Court affirmed, holding (1) Ohio Rev. Code 5713.04, read in conjunction with former Ohio Rev. Code 5713.03, requires the taxing authorities to presume that an auction sale price is not a voluntary, arm’s-length transaction, but that presumption may be rebutted by evidence that a particular sale was in fact voluntary and did occur at arm’s length; and (2) the record supported the BTA’s finding that this particular auction sale was voluntary and occurred at arm’s length. View "Olentangy Local Sch. Bd. of Educ. v. Delaware County Bd. of Revision" on Justia Law

Relators, an employee of Precision Directional Boring, LLC and his wife, commenced an action in the Cuyahoga County Common Pleas Court against Precision and Gary Cole, a coworker at Precision. Cole, a resident of Cuyahoga County, was the only party with a connection to that forum. The Cuyahoga County court granted Precision’s motion to transfer for improper venue and transferred the case to the Medina County Common Pleas Court. The case was subsequently transferred back to Cuyahoga County and then again to Medina County. Relators then filed a complaint in the court of appeals seeking writs of mandamus and procedendo to compel the Cuyahoga County court judge to vacate that court’s transfer orders and adjudicate the underlying action on the merits. The appellate court granted Relators’ motion, concluding that venue was proper in Cuyahoga County. The Supreme Court reversed, holding that Cole’s status as a nominal party prevented Relators from establishing a clear legal right to the vacation of the transfer orders in Cuyahoga county or a clear legal duty by the Cuyahoga County court judge to perform that act, and an appeal would provide an adequate remedy. View "State ex rel. Yeaples v. Gall" on Justia Law

In 2006, the City of Cincinnati filed an application for exemption from real-property tax for property that constituted part of the City’s convention center. The tax commissioner granted the exemption for 2006 but denied it for subsequent years. While the City’s appeal was pending at the Board of Tax Appeals (BTA), new legislation was enacted that provided an exemption in the present situation. Therefore, the BTA remanded the case to the tax commissioner. While the 2006 exemption application was again pending before the tax commissioner, the Cincinnati City School District Board of Education attempted to intervene as a party. The tax commissioner denied the school board’s motion to intervene and, pursuant to the newly enacted legislation, granted the exemption for 2007 and later years. The school board appealed. The BTA dismissed the appeal on the grounds that the school board lacked standing to appeal. The Supreme Court affirmed, holding that the BTA acted reasonably and lawfully in determining that the school board lacked standing to appeal because of its failure to comply with Ohio Rev. Code 5715.27(C). View "Cincinnati City Sch. Dist. Bd. of Educ. v. Testa" on Justia Law

At dispute in this case was a bridge located in Cuyahoga County on the border between Independence City and the village of Valley View and on a road that was neither a County road nor a state highway. The County and the City each claimed that the other was responsible for maintaining and repairing the bridge. The County’s duty to repair or replace such a bridge depended upon whether the road served by the bridge was a road of general and public utility. The Cuyahoga County Board of County Commissioners determined that the road was not a road of general and public utility. The common pleas court reversed, and the court of appeals affirmed. The Supreme Court affirmed, holding that a preponderance of reliable, probative, and substantial evidence supported the determination that the road was a road of general and public utility. View "City of Independence v. Office of the Cuyahoga County Executive" on Justia Law

Appellee pleaded guilty to one count of theft and was sentenced to five years of community control and ordered to pay restitution to certain third parties. Appellee later applied to have the record of her theft conviction sealed. Although the trial court recognized that Appellee had not yet satisfied her obligation to make restitution to the third parties, it granted Appellee’s application to seal her record because Appellee had paid a substantial portion of the restitution owed. The court of appeals affirmed. The Supreme Court reversed, holding (1) a trial court may not seal an offender’s record before the offender has completed all sentencing requirements, including any order to make restitution to third parties; and (2) because Appellee still owed restitution in this case, she had not received a final discharge of her conviction and could not have her records sealed. Remanded tot he trial court with instructions to vacate its prior judgment. View "State v. Aguirre" on Justia Law

Appellee, a home health nurse who provided in-home health-care services to clients of Visiting Nurse Association of Mid-Ohio (VNA), was injured in a vehicle collision while she was traveling to the home of a patient. Appellee had decided to transport her children and two friends to a mall on her way to the patient’s home. The Industrial Commission allowed Appellee’s claim for a neck sprain. VNA appealed. The trial court granted summary judgment for VNA, concluding that Appellee was on a personal errand at the time she was injured. The court of appeals reversed, concluding that the accident and injury arose out of and occurred in the course of Appellee’s employment. Specifically, the court determined that although Appellee had intended to drop her passengers off at the mall, she had the dual intent to travel to her patient’s home, and when she was injured, she had not yet diverted from that path. The Supreme Court reversed, holding that the doctrine of dual intent or dual purpose is not recognized in Ohio for purposes of determining eligibility for workers’ compensation benefits. Remanded. View "Friebel v. Visiting Nurse Ass’n of Mid-Ohio" on Justia Law

Defendant was indicted on several charges. Defendant entered into a plea agreement whereby he agreed to testify in a murder prosecution against his father in exchange for amended or dismissed charges. One year after Defendant was sentenced, the State asked the trial court to vacate Defendant’s plea because he failed to cooperate in the State’s prosecution of his father. The trial court granted the request, withdrew the former plea agreement, and vacated the sentence. Defendant subsequently entered into a second plea agreement and was resentenced. The appellate court reversed the trial court’s decision, concluding that the trial court did not have the authority to reconsider its own final judgment after Defendant had been sentenced. The Supreme Court affirmed, holding that there is no authority for a court to revisit a sentence that has already been imposed based on a defendant’s failure to fulfill his obligations under a plea agreement. View "State v. Gilbert" on Justia Law

Appellant brought an original action for a writ of mandamus against his former employers, the Summit County prosecutor and the County (collectively, the County), alleging that the County did not compensate him in accordance with established pay scales for his position and seeking payment of “an amount to cover back pay losses.” The court of appeals denied the writ and also denied Appellant’s motion for sanctions. The Supreme Court affirmed, holding (1) Appellant’s right to back pay was not so clear as to justify issuance of the extraordinary writ of mandamus, and therefore, the court of appeals correctly determined that Appellant failed to carry his burden of proof; and (2) the appellate court did not abuse its discretion in denying Appellant’s motion for sanctions. View "State ex rel. Manley v. Walsh" on Justia Law

Christopher Wright was convicted of felonious assault. The court of appeals affirmed. Asserting that he filed such a motion, Wright filed a petition for writ of procedendo to compel the trial judge to rule on his pro se motion for a new trial. The judge to whom the motion was directed moved to dismiss the motion, asserting that Defendant never filed a motion for a new trial. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that the court of appeals was correct in dismissing the petition, as there was no evidence that Wright’s motion was ever filed in the trial court. View "State ex rel. Wright v. Niehaus" on Justia Law