Justia Ohio Supreme Court Opinion Summaries

Appellants were convicted of engaging in a pattern of corrupt activity under Ohio’s version of the federal Racketeer Influenced and Corrupt Organizations Act (RICO) for their involvement in the sale of drugs. The total amount of money involved in the sales attributed to each appellant was $460 and $250 respectively. Appellants appealed, arguing that the State failed to offer evidence demonstrating that either of them was involved in drug sales that totaled $500 or more, although the enterprise they were involved in profited significantly, and therefore, the $500 threshold set forth in Ohio’s RICO statutes had not been satisfied as to either of them individually. The Supreme Court overturned Appellants’ first-degree felony convictions under Ohio’s RICO statutes, holding that in order for a defendant to obtain a conviction for engaging in a patter of corrupt activity, Ohio’s RICO statutes must be construed so that the stated threshold amount applies to each individual and not to the enterprise as a whole. Remanded.View "State v. Stevens" on Justia Law

A colorectal surgeon and a surgical resident at a hospital (collectively, Defendants), performed abdominal surgery on Plaintiff in 2007. In 2009, Plaintiff filed a medical malpractice claim against Defendants, alleging that Defendants’ negligence caused her femoral-nerve damage. The jury entered verdicts for Defendants. Plaintiff filed a motion for judgment notwithstanding the verdict, arguing that the verdicts could not be reconciled with the evidence. The trial court denied the motion. The court of appeals reversed and remanded for a new trial, holding (1) the trial court properly overruled Plaintiff’s motion for judgment notwithstanding the verdicts; but (2) the trial court erred in instructing the jury on remote cause. The Supreme Court reversed, holding that the court of appeals erroneously found prejudicial error in the remote-cause jury instruction. Remanded.View "Hayward v. Summa Health Sys./Akron City Hosp." on Justia Law

Between 1996 and 2003, Appellant filed several workers’ compensation claims, which were allowed for certain conditions. Appellant subsequently filed two applications for permanent-total-disability compensation. The Industrial Commission denied the applications, relying in part on the report of Dr. Lee Howard, a psychologist, who determined that Appellant could perform work without significant limitations. Appellant filed a complaint for a writ of mandamus, arguing that the Commission abused its discretion when it relied on Dr. Howard’s report because the report was stale. The court of appeals denied the writ, determining that Dr. Howard’s report was relevant evidence. The Supreme Court affirmed, holding that the Commission did not abuse its discretion when it relied on Dr. Howard’s report in denying permanent-total-disability compensation.View "State ex rel. Bailey v. Indus. Comm’n" on Justia Law

After a jury trial, Appellant was convicted of two counts of aggravated murder and sentenced to death. The Supreme Court affirmed, holding (1) the trial court did not abuse its discretion in finding that Appellant was competent to stand trial; (2) the trial court did not abuse its discretion in ordering Appellant to wear leg restraints in the courtroom, and even assuming that the order was an abuse of discretion, the error was harmless; (3) the trial court erred in allowing the State to introduce evidence of weapons and ammunition not used in the murders, but the error was harmless; (4) the trial court did not abuse its discretion in introducing the former testimony of Dr. Delaney Smith, a psychiatrist, during the penalty phase, as defense counsel had a prior opportunity to cross-examine Dr. Smith; and (5) the trial court’s sentencing opinion was adequate. View "State v. Neyland" on Justia Law

Robert Sheppard was injured while working for Employer. After Sheppard retired, he filed an application for permanent-total-disability (PTD) compensation, which a staff hearing officer granted. Employer filed a request for reconsideration on the basis that the staff hearing officer’s order contained mistakes of fact and law. After a hearing, the Industrial Commission issued an order confirming that the staff hearing officer’s order contained a clear mistake of law and denying the underlying request for PTD compensation. Sheppard filed a complaint for a writ of mandamus alleging that the Commission abused its discretion when it exercised continuing jurisdiction and denied PTD compensation. The court of appeals denied the writ, concluding (1) the staff hearing officer’s mistake of law was sufficient for the Commission to invoke its continuing jurisdiction; and (2) once the Commission properly invoked its continuing jurisdiction, it had authority to reconsider the issue of PTD compensation. The Supreme Court affirmed, holding (1) the staff hearing officer made a mistake of law justifying the exercise of continuing jurisdiction; and (2) the Commission’s continuing jurisdiction vested it with authority to issue a new order denying PTD compensation.View "State ex rel. Sheppard v. Indus. Comm'n" on Justia Law

Robert Corlew was an employee of Honda of America Manufacturing, Inc. when he was injured while working. Honda’s long-term-disability insurance carrier eventually determined that Corlew was not eligible for ongoing disability benefits because he was capable of gainful employment outside of Honda. Corlew subsequently retired because there was no position available at Honda. One year later, Corlew underwent surgery on his wrist. The Industrial Commission awarded temporary-total-disability (TTD) compensation to be paid during Corlew’s postsurgical recovery, concluding that Corlew had not voluntarily retired or abandoned the workforce. The court of appeals denied Honda’s request for a writ of mandamus, concluding that Corlew’s retirement was due to his industrial injury, and thus was involuntary, and that there was no evidence that Corlew had abandoned the entire workforce. The Supreme Court affirmed, holding that Corlew was eligible for TTD compensation even though he suffered no economic loss that could be directly attributed to his industrial injury.View "State ex rel. Honda of Am. Mfg., Inc. v. Indus. Comm’n" on Justia Law

Appellant was charged with aggravated murder, and his case was assigned to the docket of Common Plea Court Judge Thomas Nurre. A visiting judge, Judge Donald Schott, was assigned to preside over the trial. The jury found Appellant guilty, and the trial court sentenced Appellant to a term of life imprisonment, with the possibility of parole after twenty years. The judgment entry was signed by Judge Nurre on behalf of Judge Schott. Appellant filed an original action in the court of appeals requesting writs of mandamus and prohibition and seeking to declare the entry of conviction void because it was not signed by the judge who presided over the trial. The court of appeals dismissed the action. The Supreme Court affirmed on the basis that Appellant’s sentencing entry did not violate Ohio R. Crim. P. 32(C) because Judge Nurre’s signing the entry was proper, and the entry satisfied the requirements of Rule 32(C). View "State ex rel. Harris v. Hamilton County Court of Common Pleas" on Justia Law

While on parole from a prior conviction of murder, Appellant committed murder. After a trial in 1984, a three-judge panel found Appellant guilty of aggravated murder with a prior-conviction specification and sentenced him to death. The Supreme Court affirmed the conviction but vacated the death sentence, determining that the panel had improperly weighed a nonstatutory aggravating circumstance against the mitigating factors. On remand, the same three-judge panel that had originally sentenced Defendant conducted the resentencing hearing and again sentenced Defendant to death. The Supreme Court affirmed. In 2007, the Sixth Circuit Court of Appeals granted habeas relief and required that Defendant be resentenced on the ground that the panel on resentencing should have allowed Defendant to introduce mitigating evidence in addition to the mitigating evidence presented at his 1984 trial. By the time of the subsequent resentencing, none of the original panel members were on the bench. Accordingly, the trial court convened a three-panel consisting of three new members. The new panel again sentenced Defendant to death. Defendant appealed, raising five propositions of law challenging his death sentence. The Supreme Court affirmed the death sentence, holding that all five propositions of law lacked merit. View "State v. Davis" on Justia Law

Appellant submitted a declaration of candidacy to run in the May 6, 2014 primary for an elected position on the Democratic Party State Central Committee and, along with the declaration, submitted a nominating petition containing nine total signatures. The Franklin County Board of Elections rejected Appellant’s declaration because, according to the Board’s judgment, Appellant did not submit five valid signatures to qualify for the ballot. After Appellant unsuccessfully appealed, Appellant filed a complaint for writ of mandamus with the court of appeals. The court denied the writ. The Supreme Court granted the writ and ordered the Board to add Appellant’s name to the May 6, 2014 primary ballot, holding that the Board abused its discretion in determining that the nominating petition did not contain five valid signatures.View "State ex rel. Scott v. Franklin County Bd. of Elections" on Justia Law

Appellant was found guilty of four felonies, with forfeiture specifications, for running a marijuana-distribution operation out of a building he and his brothers owned on Scranton Road. Common Pleas Court Judge Nancy McDonnell issued a sentencing entry listing the property at Scranton Road as property to be forfeited. On October 11, 2011, Appellant appealed the sentencing order. On January 13, 2012, Judge McDonnell issued a journal entry reiterating Appellant’s sentence and ordering transfer of the property. On October 23, 2012, Appellant sought a writ of prohibition to vacate Judge McDonnell’s January 13, 2012 order, arguing that Judge McDonnell lacked jurisdiction to enter the order. The court of appeals dismissed Appellant’s petition, concluding that Ohio Rev. Code 2981.04 vested Judge McDonnell with jurisdiction to conduct forfeiture proceedings even after the notice of appeal was filed. The Supreme Court affirmed, holding that Judge McDonnell did not patently and unambiguously lack jurisdiction and that any errors in the proceedings should be addressed on appeal. View "State ex rel. West v. McDonnell" on Justia Law