Justia Ohio Supreme Court Opinion Summaries

Defendants executed a promissory note in favor of FirstMerit Bank secured by a mortgage on several parcels of real estate. After Defendants defaulted on the promissory note, FirstBank initiated foreclosure proceedings. The common pleas court entered a decree in foreclosure, and the properties were sold at auction. Because the sale of the properties resulted in a deficiency, FirstMerit obtained a cognovit judgment against Defendants. Defendants moved for relief from judgment pursuant to Ohio R. Civ. P. 60(B), asserting as a defense that they had reached an oral settlement agreement with FirstMerit under which FirstMerit had agreed to cease legal proceedings and release Defendants from their obligations. The trial court denied the motion, concluding that the statute of frauds barred their defense. The appellate court reversed, determining that Ohio Rev. Code 1335.05 did not prohibit Defendants from raising as a defense that the parties orally agreed to modify the terms of their agreement. The Supreme Court reversed, holding that the oral agreement in this case fell within the statute of frauds, and therefore, Defendants were precluded from raising the agreement as a defense in a motion for relief from judgment. View "FirstMerit Bank, N.A. v. Inks" on Justia Law

Defendant pled no contest to aggravated robbery, robbery, and aggravated possession of drugs. The sentencing court imposed a term of imprisonment and $19,000 in fines. Defendant appealed his sentence, and Defendant’s newly-appointed appellate counsel moved to view and supplement the record with the presentence investigation report. The court of appeals denied the motion to disclose the report to Defendant’s appellate counsel. The Supreme Court reversed, holding (1) the term “defendant’s counsel” as used in Ohio Rev. Code 2951.03, which permits a defendant’s counsel to inspect and use a presentence investigation report, encompasses both a defendant’s trial counsel and a defendant’s appellate counsel; and (2) therefore, under section 2951.03, Defendant’s appellate counsel was entitled to obtain a copy of Defendant’s presentence investigation report. View "State v. Johnson" on Justia Law

Appellant, an inmate, filed a motion for leave to amend his omnibus motion, which the trial court did not rule on. The court of appeals remanded for a ruling on the motion, but the court’s entry mistakenly indicated Appellant’s motion was one to withdraw his guilty plea. The court then corrected its mistake. Unaware of the correction, the trial court recognized the court of appeals’ error and denied Appellant’s motion for leave. Appellant then filed petitions for writs of mandamus and/or procedendo in the court of appeals to compel the trial court to rule on his motion for leave to amend. The court of appeals dismissed the first petition as procedurally defective and the second petition as moot because the trial court did rule on the motion for leave. The court also revoked Appellant’s in forma pauperis privileges due to his “repetitious and frivolous conduct.” The Supreme Court affirmed in part and reversed in part, holding (1) the dismissal of Appellant’s first mandamus/procedendo action did not operate as res judicata, but, on the merits, Appellant was not entitled to an extraordinary writ; and (2) Appellant’s complaint did not warrant a revocation of his in forma pauperis privileges. View "State ex rel. Brown v. Logan" on Justia Law

In 2010, Appellee was convicted of a drug offense and a related offense and sentenced to eleven years in prison. In late 2010, Appellee’s convictions were reversed. Appellee was released on bond and the charges against him were dismissed. Appellee then filed a complaint asserting that he was a wrongfully imprisoned individual. The trial court dismissed the complaint, but the court of appeals reversed, concluding that Appellee satisfied all five requirements of Ohio Rev. Code 2743.48(A)(1) through (5). The Supreme Court reversed, holding (1) when a defendant seeks a declaration that he is a wrongfully imprisoned individual and seeks to satisfy subsection 2743.48(A)(5) by proving that an error in procedure resulted in his release, the error in procedure must have occurred subsequent to sentencing and during or subsequent to imprisonment; and (2) Appellee did not satisfy subsection 2743.48(A)(5) in this case. View "Mansaray v. State" on Justia Law

Appellant had been employed as a nurse with Progressive Parma Care, LLC since 1995. During her tenure at Parma Care, Appellant was disciplined on several occasions. On April 10, 2008, Appellant was injured at work. On April 16, 2008, the director of nursing terminated Appellant for cause. On April 21, 2008, a physician certified that Appellant was temporarily and totally disabled from all employment beginning on the date of her injury. The Industrial Commission denied Appellant’s request for temporary total disability (TTD) compensation, concluding that Appellant’s discharge from employment for violating written workplace rules had been a voluntary abandonment, making Appellant ineligible for benefits, and that the medical evidence did not support Appellant’s claim that she had been temporarily and totally disabled at the time of her termination. Appellant filed a complaint for a writ of mandamus, alleging that the Commission had abused its discretion when it denied her request for TTD compensation. The court of appeals denied the writ. The Supreme Court affirmed, holding that the Commission did not abuse its discretion when it denied Appellant compensation for TTD. View "State ex rel. Robinson v. Indus. Comm'n " on Justia Law

In 2003, Appellant was tried on charges of aggravated burglary and rape. A mistrial was declared due to a hung jury. After a retrial in 2005, Appellant was convicted by a jury of both charges. Appellant’s convictions were affirmed on direct appeal. Appellant subsequently asked the court of appeals to issue a writ ordering immediate release or a new trial, alleging that the retrial was jurisdictionally unauthorized because, in 2003, the trial court had discharged the jury without satisfying the requirement of Ohio Rev. Code 2945.36 that the reasons for the discharge be entered on the journal. However, Appellant failed to raise this objection before his second trial. The court of appeals’ dismissed Appellant’s petition. The Supreme Court affirmed, holding that Appellant waived his mistrial argument, and moreover, Appellant had other adequate legal remedies at law. View "State ex rel. Bevins v. Cooper" on Justia Law

Appellant purchased property in 2004 for $7.4 million. For the tax-year 2006, the County auditor set the value at $8 million. Appellant filed a complaint with the County Board of Revision (BOR) seeking a decrease in value to $5 million, an amount close to the sale price of the property in 2003. After a hearing, the BOR reduced the property value from $8 million to the 2004 sale price of $7.4 million. Appellant appealed to the Board of Tax Appeals (BTA). The BTA upheld the $7.4 million sale price as the best evidence of value. The Supreme Court affirmed, holding that the BTA’s decision to adopt the $7.4 million sale price from 2004 as the property’s value for the tax-year 2006 was not unreasonable or unlawful. View "HIN, LLC v. Cuyahoga County Bd. of Revision" on Justia Law

In 2003, Appellant was arrested and charged with the murder of Amber Zurcher. The trial court granted a mistrial on Appellant’s first trial. Several trials followed, and after a fifth trial, another mistrial was declared. When the trial court set a sixth trial date, Defendant moved to dismiss the indictment, arguing that the prosecution was barred by the Double Jeopardy and Due Process Clauses of the U.S. Constitution. The trial court denied the motion. The State moved to dismiss Appellant’s appeal, arguing that the trial court’s denial of Appellant’s motion to dismiss was not a final, appealable order. The court of appeals concluded that, in this situation where there had been multiple mistrials, the order was a final, appealable order. The Supreme Court affirmed, holding that an order denying a motion to dismiss on double-jeopardy grounds is a final, appealable order. Remanded. View "State v. Anderson" on Justia Law

Appellant was injured while working for Employer. Appellant’s workers’ compensation claim was allowed for a dislocated left shoulder and a torn left rotator cuff, among other injuries. Appellant later requested compensation for the scheduled loss of use of his left upper extremity. The Industrial Commission denied Appellant’s request for benefits by relying on the report of Dr. D. Ann. Middaugh as evidence that Appellant had retained some use of his left arm. Appellant filed a complaint for a writ of mandamus alleging that the Commission’s finding as an abuse of discretion. The court of appeals denied the writ, concluding that Dr. Middaugh’s report was some evidence upon which the Commission could rely to deny scheduled loss compensation. The Supreme Court reversed, holding that Appellant was entitled to an award for the scheduled loss of his left arm because (1) Dr. Middaugh’s findings were not consistent with her ultimate conclusion, and consequently, Dr. Middaugh’s report could not be some evidence supporting the Commission’s decision to deny an award for loss of use; and (2) the only other report submitted for consideration with Appellant’s loss-of-uses award stated that, for all practical purposes, Appellant had lost the function of his left arm. View "State ex rel. Wyrick v. Indus. Comm'n of Ohio" on Justia Law

Appellant made a public-records request to the City of South Euclid. After the City failed to respond to the request for nearly six months, Appellant filed a claim for a writ of mandamus. The writ claim became moot when all the requested records were produced during the pendency of the mandamus action. Appellant claimed the she was entitled to statutory damages and attorney fees given that (1) the city delayed two months in providing any response to the request, and (2) the original production of documents was incomplete. The court of appeals denied both statutory damages and attorney fees, concluding that Appellant “failed to establish any viable public benefit.” The Supreme Court (1) reversed the court of appeal’s denial of statutory damages, holding that in authorizing an award of such damages, Ohio Rev. Code 149.43(C)(1) does not condition that award on applying the public-benefit test; and (2) affirmed the denial of attorney fees but on other grounds, holding that the plain language of section 149.43(C)(2)(b) prohibited an award of attorney fees in this case. Remanded. View "State ex rel. DiFranco v. City of S. Euclid" on Justia Law