Justia Ohio Supreme Court Opinion Summaries

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

In 1994, Appellant was convicted of several offenses associated with a robbery spree through Ohio and Michigan. In 2013, Appellant filed a petition for habeas corpus, arguing that because he was transferred to Michigan on a detainer to serve his sentence there, Ohio lost jurisdiction over him. The court of appeals dismissed the petition for failure to state a claim upon which relief can be granted, concluding that because Appellant had yet to serve his maximum Ohio term, which will expire in 2019, Appellant had failed to show that he was entitled to immediate release. The Supreme Court affirmed, holding that Appellant had not yet served his maximum twenty-five-year sentence sentence imposed in 1994, and therefore, habeas relief was not appropriate. View "State ex rel. Abercrombie v. Cuyahoga County Court of Common Pleas" on Justia Law

Appellants, private individuals, filed this case in quo warranto in the Tenth District Court of Appeals to oust certain individuals from the board of directors of the Omar Ibn El Khattab Mosque, Inc. The members of the board filed a motion for summary judgment arguing that Appellants lacked standing to bring such an action against the officers of a not-for-profit corporation. The court of appeals agreed and dismissed the complaint. The Supreme Court affirmed, holding that the court of appeals correctly denied the petition because private persons have no standing to institute an action in quo warranto to oust officers of a private, not-for-profit corporation. View "State ex rel. Salim v. Ayed" on Justia Law

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