Justia Ohio Supreme Court Opinion Summaries

This case involves a dispute over a public records request made by the relator, Thomas Clark, an inmate at Lebanon Correctional Institution. Clark sent a request to the Ohio Department of Rehabilitation and Correction (ODRC) for an up-to-date paper copy of the commissary price list for each commissary window at the prison. After several failed attempts to obtain the information through internal procedures, and despite an assurance from an inspector that he would provide the requested lists, Clark had still not received the paper copies. He therefore filed a mandamus action to compel the ODRC to provide the records.The Supreme Court of Ohio denied the writ of mandamus as moot because the ODRC had already provided Clark with the records he requested. However, the court found that the ODRC had failed to comply with its obligations under Ohio's Public Records Act, R.C. 149.43, for 11 business days starting from the day Clark filed the mandamus action. Accordingly, the court awarded Clark $1,000 in statutory damages, the maximum amount allowed under the statute. The court declined to award court costs, finding no evidence of bad faith on the part of the ODRC. View "State ex rel. Clark v. Dept. of Rehab. & Corr." on Justia Law

In response to the COVID-19 pandemic, Ohio State University suspended in-person instruction, transitioned to virtual learning, restricted campus access, and provided limited refunds to students. Brooke Smith, a student at the university, filed a class-action lawsuit against the university, alleging breach of contract, unjust enrichment, and conversion. Smith argued that students had lost the benefits of their education without sufficient refunds.The Supreme Court of Ohio considered whether discretionary immunity, which shields the state from lawsuits for certain highly discretionary decisions, was a jurisdictional bar or an affirmative defense to suits brought against the state. The court held that discretionary immunity was indeed a jurisdictional bar, not an affirmative defense. This means that when the state makes highly discretionary decisions, such as its response to the COVID-19 pandemic, the Court of Claims does not have jurisdiction as the state has not waived its sovereign immunity for those decisions.However, the court noted that discretionary immunity is not absolute and does not extend to the negligent actions of the state's employees and agents in the performance of these activities. The court reversed the judgment of the Tenth District Court of Appeals, which had found that discretionary immunity was an affirmative defense, and remanded the case back to that court to determine whether Ohio State University was protected by discretionary immunity in its response to the COVID-19 pandemic. View "Smith v. Ohio State Univ." on Justia Law

In a case before the Supreme Court of Ohio, the defendant was accused of setting up a fake car sale, during which he threatened two women with a gun and stole money. The defendant was convicted of robbing both women and illegally possessing a firearm. On appeal, the First District Court of Appeals overturned these convictions, arguing that the defendant could not be convicted of robbing the woman who was not directly holding the money. Furthermore, the court held that the defendant's rights were violated when the state used information at trial that was not previously disclosed to the defense.The Supreme Court of Ohio reversed the lower court's decision. Firstly, the court clarified that under the state's robbery statute, a person can be convicted of robbery if they commit a theft offense and threaten physical harm to another person, even if the person threatened is not the same as the theft victim. As such, both women were properly considered as victims of robbery. Secondly, the court determined that the defendant had forfeited his claim to a violation of his rights, as he failed to raise the issue of undisclosed evidence at the trial level.The case was remanded back to the First District Court of Appeals to consider the defendant's remaining assignments of error. View "State v. Brown" on Justia Law

The case revolves around a worker's compensation claim by appellant, Loretta Dillon, against the Industrial Commission of Ohio and others. Dillon had received temporary-total-disability (TTD) compensation for a work-related back injury, which was subsequently reversed on appeal after it was determined that she had reached maximum medical improvement and was no longer temporarily disabled. As a result, R.C. 4123.511(K) required the Bureau of Workers’ Compensation to recoup the overpayment of compensation that Dillon had received after she had reached maximum medical improvement.Dillon appealed this determination to the Tenth District Court of Appeals, seeking a writ of mandamus to compel the commission to vacate the order that declared an overpayment of TTD compensation and to issue a new order dissolving the overpayment. The court of appeals denied the writ, and the Supreme Court of Ohio affirmed this decision.The Supreme Court held that the plain language of R.C. 4123.511(K) required the bureau to recoup the overpayment of TTD compensation payments that Dillon received after she reached maximum medical improvement from any future benefits she might receive. It further overruled a previous case, State ex rel. Russell v. Indus. Comm, which Dillon relied on for her argument that recoupment was not warranted, stating that the reasoning in that case ran counter to the plain language of R.C. 4123.511(K) and R.C. 4123.56(A). View "State ex rel. Dillon v. Indus. Comm." on Justia Law

The case in discussion was brought before the Supreme Court of Ohio and involved an inmate, Kimani E. Ware, who filed an original action in mandamus under Ohio’s Public Records Act, R.C. 149.43. Ware sought to compel the Summit County Clerk of Courts, Tavia Galonski, to provide documents in response to a public-records request and sought an award of statutory damages under R.C. 149.43(C)(2). Ware alleged that he sent the request by certified mail in May 2022 and that the clerk’s office received the request in June 2022. The clerk asserted that her office did not receive Ware’s public-records request and that her office sent the requested records to Ware only after he filed his complaint in February 2023.The court denied Ware's motions, denied the mandamus claim as moot, and denied the request for statutory damages. The court found that Ware's mandamus claim was moot as the requested records had been provided. The court also found that Ware had not proven by clear and convincing evidence that he delivered his public-records request to the clerk by certified mail and that the clerk failed to comply with an obligation under R.C. 149.43(B). Therefore, Ware was not entitled to statutory damages. Further, the court found no evidence of bad faith on the part of the clerk. View "State ex rel. Ware v. Galonski" on Justia Law

The Supreme Court of Ohio denied a writ of mandamus brought by Kimani E. Ware, an inmate at the Trumbull Correctional Institution (TCI), against Lori Beggs, the manager of TCI's cashier’s office, and TCI itself. Ware had requested certain public records related to his personal account at TCI, and claimed that he had not received the requested documents. Beggs, however, provided evidence that she had printed and mailed the requested records. The court found that Ware did not provide clear and convincing evidence that Beggs failed to send the requested records, and concluded that the mandamus claim was moot because Beggs had fulfilled her duty by mailing the records. The court also denied Ware's request for statutory damages because he did not meet the necessary burden of proof to demonstrate that Beggs failed to comply with her obligations under the Public Records Act at the time he filed the action. View "State ex rel. Ware v. Beggs" on Justia Law

In the case of State v. Nicholson, the Supreme Court of Ohio affirmed the defendant's convictions and death sentences for the aggravated murders of two individuals. The court found that the evidence was sufficient to support the convictions, as it demonstrated that the defendant acted with prior calculation and design. Additionally, the court found no error in the trial court's decision to admit certain evidence, such as photographs from the crime scene and testimonies about the defendant's relationships with the victims. Furthermore, the court rejected the defendant's arguments regarding the adequacy of the jury instructions and the admission of victim-impact evidence, among other issues. The court concluded that the defendant did not establish any grounds for reversal of his convictions or sentences. View "State v. Nicholson" on Justia Law

The Supreme Court of Ohio denied a request from Jeryne Peterson, the mayor of Buckeye Lake, for writs of prohibition and mandamus against the Licking County Board of Elections and its members, the Fairfield County Board of Elections and its members, and the village of Buckeye Lake and its council president, Linda Goodman. Peterson was seeking to prevent a scheduled recall election from taking place.The court found that Peterson failed to show that she was entitled to a writ of prohibition preventing the village from setting the recall-election date or preventing the respondent boards of elections from conducting that election. She also failed to show that she was entitled to a writ of mandamus ordering the respondent boards of elections to remove the recall election from the ballot. The court also denied Peterson’s motion to disqualify the village’s attorney. View "State ex rel. Peterson v. Licking County Board of Elections" on Justia Law

In this case, the Supreme Court of Ohio considered whether a juvenile, T.D.S., knowingly, intelligently, and voluntarily waived his Miranda rights before providing statements to the police. The statements related to a homicide investigation involving another juvenile.The case originated from an incident in 2019, where the Police responded to a report of shots fired in an apartment building and discovered a male juvenile, S.G., with gunshot wounds. The police investigation led them to T.D.S., who was then 15 years old. During questioning at T.D.S.'s mother’s house, T.D.S. initially denied involvement in the shooting but later admitted to accidentally shooting S.G. while playing with a gun. After these statements, T.D.S. was read his Miranda rights and questioned further. He was subsequently charged with several offenses including murder and felonious assault.T.D.S. argued that the juvenile court should have granted a motion to suppress all the statements he made to the police officers, contending that he did not knowingly, intelligently, and voluntarily waive his Miranda rights. After considering the totality of the circumstances, including T.D.S.'s age, prior criminal experience, and the nature of the police interrogation, the Supreme Court of Ohio affirmed the lower courts' decisions that T.D.S. had knowingly, intelligently, and voluntarily waived his Miranda rights. The court found that the police did not engage in coercion and that T.D.S.'s waiver was not involuntary.T.D.S. also argued that his post-Miranda statements should be presumed inadmissible under the court's previous reasoning in a case called State v. Farris. However, the court found that T.D.S. had not properly raised this argument in the lower courts, so it was forfeited. Even if he had preserved the argument, the court found that the record did not support his claims under the Farris case.Therefore, the court affirmed the judgment of the lower courts, finding that T.D.S.'s post-Miranda statements were properly admitted at trial. View "In re T.D.S." on Justia Law

In December 2019, a taxicab driver, Phillip Palmer, shot a heavily intoxicated passenger, Nicholas Young, following a dispute over cab fare. The incident escalated into a physical altercation at a gas station, where Young shoved Palmer twice, causing him to fear for his life. Palmer, who had begun carrying a gun in his cab after hearing about a driver who had been shot by a passenger, fired two shots at Young, hitting him in the neck. Young survived his injuries. At trial, Palmer admitted to the shooting but claimed self-defense. The trial court denied Palmer's request for a self-defense jury instruction, finding Palmer's statements about his means of escape not credible and determining that a reasonable person would not have believed they were in danger of being killed by Young under the circumstances. Palmer was acquitted of attempted murder but found guilty of felonious assault and a firearm specification.The Supreme Court of Ohio reversed the decision of the Twelfth District Court of Appeals, which had affirmed the trial court's judgment. The Supreme Court determined that the trial court had improperly weighed the evidence when performing a sufficiency analysis. The court found that Palmer had presented legally sufficient evidence for each element of self-defense and was therefore entitled to a self-defense jury instruction. The evidence presented, if believed, could convince a trier of fact that Palmer was acting in self-defense. Therefore, the case was remanded for a new trial on the felonious-assault charge and accompanying firearm specification. View "State v. Palmer" on Justia Law