Justia Ohio Supreme Court Opinion Summaries

At issue in this case was a commercial building consisting of a warehouse and office space. The tax year at issue was 2005. The property owner disagreed with the auditor’s valuation of the subject property and filed a complaint seeking a reduction. Before the Board of Revision (BOR) the owner presented a value using the income approach as an “owner’s opinion of value.” The BOR found the valuation evidence “competent, credible, and probative” and adopted the value suggested by that approach. The Board of Tax Appeals (BTA) reinstated the auditor’s determination of value, determining that the income-approach valuation did not qualify as an admissible owner’s opinion and was not probative evidence of value in any event. The Supreme Court reversed the decision of the BTA, holding (1) certain expert testimony coupled with the income-approach valuation was competent evidence of value; and (2) the BTA may not revert to the auditor’s value when the BOR relied on competent evidence. View "Worthington City Schs. Bd. of Educ. v. Bd. of Revision" on Justia Law

In 2010, almost ten years after he had left his employment with his employer, Formica Corporation, Appellant applied for temporary-total-disability (TTD) compensation. The Industrial Commission denied Appellant’s application, concluding that Appellant’s failure to search for work since leaving Formica was evidence that he had abandoned the job market and retired, making him ineligible to receive further compensation. Appellant filed a complaint for a writ of mandamus. The court of appeals denied the writ, concluding that the evidence supported the Commission’s decision that Appellant intended to voluntarily abandon the workforce when his employment with Formica ended. The Supreme Court affirmed, holding that the court of appeals did not err when it determined that the Commission’s order was supported by sufficient evidence that Appellant had already abandoned the entire workforce when he applied for TTD compensation in 2010. View "State ex rel. Floyd v. Formica Corp." on Justia Law

The new owner of an arena football team applied for workers’ compensation coverage. The Bureau of Workers’ Compensation concluded that the new owner was a successor employer for workers’ compensation purposes and that it would base the new owners’ premium rate on the experience of the former owner. The new owner filed a complaint for a writ of mandamus alleging that the Bureau abused its discretion by finding that the new owner was a successor to the former owner for workers’ compensation purposes and by failing to adequately explain its decision. A magistrate concluded that the Bureau abused its discretion in transferring the entire experience of the former owner, concluding that if only a portion of the former owner’s business was transferred to the new owner, then the experience rating is transferred in proportion to the business that was transferred. The court of appeals agreed with the magistrate’s decision and granted the new owner’s request for a writ. The Supreme Court affirmed, holding that the Bureau abused its discretion by transferring the entire experience rating of the former owner. View "State ex rel. Cleveland Prof’l Football, LLC v. Buehrer" on Justia Law

Petitioner, an inmate, filed a petition for a writ of habeas corpus challenging the calculation of his jail-time credit and contending that aggregation of his sentences constituted double jeopardy. The court of appeals dismissed Petitioner’s claims. The Supreme Court affirmed, holding (1) habeas corpus does not lie to challenge the calculation of jail-time credit when a petitioner has an adequate remedy by appeal to raise the issue; (2) double jeopardy claims are not cognizable in habeas corpus; and (3) because Petitioner was not entitled to immediate release he failed to state a claim in habeas. View "Johnson v. Crutchfield" on Justia Law

The Board of Commissioners on Grievances and Discipline of the Supreme Court of Ohio filed with the Supreme Court a certified copy of a judgment entry of a felony conviction against Rosenfield, a Cleveland attorney licensed to practice law in the state of Ohio. The court suspended Rosenfield from the practice of law for an interim period, pending disciplinary counsel’s investigation and the commencement of disciplinary proceedings. View "In re Rosenfield" on Justia Law

At issue in this appeal was whether a trial court must engage in judicial fact-finding prior to imposing consecutive sentences on an offender. In this case, Appellant was sentenced to consecutive sentences aggregating eight years and five months for convictions arising out of four instances in which Appellant took $117 in change from vending machines. On appeal, Appellant argued that the imposition of consecutive sentences was contrary to law because the trial court did not expressly make the findings mandated by Ohio Rev. Code 2929.14(C)(4) and did not provide reasons in support of those findings when imposing consecutive sentences. The Supreme Court vacated the sentence and remanded for resentencing, holding (1) a trial court is required to make the findings required by section 2929.14(C)(4) at the sentencing hearing and incorporate its findings into its sentencing entry, but the court has no obligation to state reasons to support its findings; and (2) the trial court in this case did not make all of the findings required by section 2929.14(C)(4) at the time it imposed consecutive sentences, and neither did it incorporate all of the necessary findings into its judgment entry. Remanded for resentencing. View "State v. Bonnell" on Justia Law

In these two consolidated cases, the trial court sentenced a felony offender to one or more community-control sanctions without first ordering and reviewing a presentence investigation report. In both cases, the sanction ordered was a sentence of pre-trial jail time served following a plea. The Supreme Court entered judgment in favor of the defendants in both cases, holding that, although requiring a presentence investigation for every felony conviction when the offender is not sent to prison is excessive and unwarranted, a trial court acts contrary to law when it imposes a sentence of one or more community-control sanctions on a felony offender without first ordering and reviewing a presentence investigation report. View "State v. Amos" on Justia Law

In 2007, Appellant was convicted and sentenced to prison. In 2013, Appellant filed a petition for a writ of procedendo against Judge James D. Jensen, asserting that Judge Jensen failed to rule on a motion to dismiss the indictment in his criminal matter. The court of appeals sua sponte dismissed the petition for the writ because there was no indication that the motion to dismiss had been filed. The Supreme Court affirmed but for a different reason, holding that Appellant’s petition was fatally defective because Appellant named the wrong party as the respondent, where Judge Michael Goulding was currently assigned to Appellant’s case in the court of common pleas. View "State ex rel. Johnson v. Jensen" on Justia Law

Appellant was ordered to pay restitution to several victims as part of his sentence for a criminal conviction. Thereafter, Appellant filed a petition for a writ of mandamus seeking public records, claiming that despite several requests, Appellee failed to provide him with certified copies of the victim-loss statement for each victim. The court of appeals issued an alternative writ ordering Appellee to respond to the complaint, to which Appellee responded that she was not and had ever been in possession of the documents Appellant was seeking. The court of appeals subsequently dismissed the petition. The Supreme Court affirmed, holding that the court of appeals properly dismissed the petition because Appellant failed to file the documentation required by Ohio Rev. Code 2969.25 with his petition and because he failed to show that the victim-loss statements that he requested existed. View "State ex rel. Gooden v. Kagel" on Justia Law

In 2010, the juvenile court found H.V. to be delinquent and committed him to a minimum six-month term commitment to the Ohio Department of Youth Services (ODYS). H.V. was subsequently placed on supervised release. Thereafter, H.V. was charged with second-degree felonious assault and with violating the terms of his supervised release. The juvenile court judge revoked H.V.’s supervised release and committed him to a minimum ninety-day commitment to the ODYS. Five days later, the judge found H.V. to be delinquent and committed him to the ODYS for a minimum one year commitment. The court ordered that the ninety-day term imposed for the violation of supervised release would run consecutively to the one-year term imposed for the felonious assault. The Supreme Court affirmed, holding (1) a juvenile court has the authority to commit a delinquent juvenile to the ODYS for a minimum period in excess of thirty days for violating his supervised release; and (2) in committing a juvenile to the ODYS for a supervised-release violation, a juvenile court can order that the commitment period be served consecutively to the commitment period imposed for that crime that resulted in the violation of supervised release. View "In re H.V." on Justia Law