Justia Ohio Supreme Court Opinion Summaries

The Indian Hill Exempted Village School District Board of Education (BOE) passed a resolution to convert 1.25 inside mills from operating levies to permanent-improvement levies. The conversion had the effect of increasing the effective rate of taxation under the “outside millage,” resulting in the district experiencing a net increase of revenue and the district’s taxpayers experiencing an increased burden. The Hamilton County Budget Commission approved to the conversion of the inside mills. The Board of Tax Appeals affirmed. The Supreme Court reversed, holding that because the BOE did not demonstrate that the revenue derived from the increased effective rate of taxation under the outside mills was necessary to cover operating expenses during the ensuing fiscal year, the BOE did not meet the requirements of Ohio Rev. Code 5705.341. View "Sanborn v. Hamilton County Budget Comm’n" on Justia Law

In 2004, Appellant was found guilty of several offenses. Appellant appealed and filed several other actions based on the judgment. Nearly a decade later, Appellant filed a complaint for writ of mandamus in the court of appeals, arguing that the original sentencing entry was never file-stamped and therefore was not a final, appealable order. Appellant sought to compel the Hamilton County Clerk of Courts to file-stamp the original sentencing entry. The court of appeals dismissed the action. The Supreme Court affirmed, holding that Appellant failed to show that the 2004 entry was not file-stamped and was not a final, appealable order. View "State ex rel. Smith v. Winkler" on Justia Law

Ohio Rev. Code 2929.20 provides that a prisoner cannot apply for judicial release until a period of time after the expiration of all mandatory prison terms in the stated prison sentence. Shawn Ware pleaded guilty to two counts of trafficking in crack cocaine. One count was a second-degree felony. Ware’s second-degree felony carried a mandatory prison term. The trial court imposed a four-year prison term for that offense. Ware later sought judicial release, arguing that he was eligible for release before the expiration of his four-year term because the original sentencing entry imposed only a minimum mandatory sentence of two years. The trial court granted the motion, explaining that it had not intended to make all four years of Ware’s sentence mandatory. The Supreme Court reversed, holding that Ware was not eligible for judicial release because his entire sentence was mandatory, and the trial court could not impose a different sentence under Ohio law. View "State v. Ware" on Justia Law

Cqualin Hawkins pleaded guilty to burglary, domestic violence, and assault. Hawkins was sentenced to four years on the burglary charge. Hawkins was later released on community control. While on community control, Hawkins was sentenced to three years for committing a new domestic violence offense. Because of the new crime, Hawkins’s community control release was evoked and his original sentence was reimposed. Hawkins filed this petition for writs of mandamus and habeas corpus asserting that the Ohio Department of Rehabilitation and Correction miscalculated his jail-time credit. The Supreme Court dismissed Hawkins’s habeas petition because it was moot, as Hawkins was no longer in custody at the time of this opinion, and dismissed Hawkins’s complaint for writ of mandamus because of flaws in the complaint. View "State ex rel. Hawkins v. Haas" on Justia Law

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