Justia Ohio Supreme Court Opinion Summaries

A patient alleged that she suffered a neck fracture after falling from her hospital bed while medicated and unattended at a hospital. She filed a complaint against the hospital within the one-year statute of limitations for medical claims, also naming ten John Doe defendants described as unknown medical providers involved in her care. The hospital was served and answered the complaint, but the plaintiff did not obtain summonses or attempt service on the John Doe defendants. Several months later, with the hospital’s consent, she amended her complaint to replace the John Doe defendants with specific individuals and entities, including two doctors and a medical group.The newly named defendants moved to dismiss, arguing that the claims against them were time-barred because they were not named before the statute of limitations expired and the plaintiff had not complied with Ohio Civil Rule 15(D), which governs the naming and service of unknown defendants. The Richland County Court of Common Pleas granted the motion, holding that the statutory 180-day extension for joining additional defendants in medical-claim actions did not apply to defendants who were “obvious” at the outset and that the plaintiff was required to comply with Civil Rule 15(D). The Fifth District Court of Appeals reversed, finding that the statutory extension applied to any additional defendants not named in the original complaint, regardless of whether their existence was contemplated at filing.The Supreme Court of Ohio affirmed the appellate court’s decision. It held that a plaintiff is not required to comply with Civil Rule 15(D) to name additional defendants in an amended complaint under R.C. 2323.451(D)(1), and that the 180-day extension under R.C. 2323.451(D)(2) is not limited to newly discovered defendants. Because the plaintiff properly amended her complaint to join the additional defendants, the extension applied and her action was timely commenced. View "Lewis v. MedCentral Health Sys." on Justia Law

The case concerns a defendant who was convicted by a jury of multiple sexual offenses, including rape, against his young daughter. The central issue on appeal relates to the jury selection process, specifically whether the defendant’s trial counsel was constitutionally ineffective for failing to challenge a particular juror, referred to as Juror McCarthy, for cause. During voir dire, Juror McCarthy expressed some initial uncertainty about his ability to be impartial in a case involving a child witness and indicated discomfort with the presumption of innocence, but also participated in group responses affirming his willingness to be fair and follow the law.After conviction, the defendant appealed to the Twelfth District Court of Appeals, arguing that his counsel’s failure to challenge Juror McCarthy deprived him of a fair trial. The appellate court reviewed the voir dire transcript and concluded that Juror McCarthy’s statements reflected an internal struggle common to many jurors faced with difficult subject matter, rather than actual bias against the defendant. The court also noted that Juror McCarthy, through group responses and direct questioning, indicated he could be fair and impartial. The appellate court therefore rejected the ineffective assistance claim and affirmed the convictions.The Supreme Court of Ohio reviewed the case, focusing on whether a reviewing court may consider group answers during voir dire when determining actual juror bias, and whether a juror who expresses partiality can be rehabilitated through such group responses. The court held that, in assessing actual bias, the entire voir dire record—including group answers—must be considered. The court found that the defendant failed to demonstrate that Juror McCarthy was actually biased, and thus did not establish ineffective assistance of counsel. The Supreme Court of Ohio affirmed the judgment of the Twelfth District Court of Appeals. View "State v. Rogers" on Justia Law

The case concerns a lawsuit brought by the executor of an estate against a city, alleging that the city’s negligence in failing to address a hazardous tree led to a fatal accident. The estate claimed that the city owned the tree and had ignored repeated warnings about its dangerous condition, resulting in the decedent’s severe injury and subsequent death after a tree fell on him while he was riding a motorcycle on a city street.After the complaint was filed, the city submitted an answer denying the allegations and raising several defenses, including a general assertion that the complaint failed to state a claim upon which relief could be granted. However, the city did not specifically assert political-subdivision immunity as a defense. The case experienced delays due to a judge’s recusal and the COVID-19 pandemic. As the case progressed, the estate pursued discovery and moved for partial summary judgment. The city failed to timely respond to discovery and only raised the political-subdivision immunity defense for the first time in an untimely motion for summary judgment, after the deadlines for dispositive motions had passed. The trial court struck the city’s motion and later denied the city’s request for leave to amend its answer to add the immunity defense, finding the delay unjustified and prejudicial.The Seventh District Court of Appeals affirmed the trial court’s decision, holding that the city’s general assertion of failure to state a claim did not preserve the specific defense of political-subdivision immunity, and that the trial court did not abuse its discretion in denying leave to amend the answer. The Supreme Court of Ohio agreed, holding that a party does not preserve the defense of political-subdivision immunity under R.C. Chapter 2744 by merely asserting failure to state a claim, and that unjustified and prejudicial inaction supported the denial of leave to amend the answer. The judgment of the court of appeals was affirmed. View "Durig v. Youngstown" on Justia Law

Nathan Gault was a party to a divorce action in the Medina County Court of Common Pleas. After the case concluded, the clerk charged him various fees, including a “Clerk Computer Operation” fee. Gault believed he had been overcharged, specifically challenging the additional dollar per page fee assessed for making a complete record of the proceedings. He filed a class-action complaint against the clerk, the county treasurer, and the county itself, alleging that the clerk charged him $125 in computer-operation fees, which was over $100 more than statutorily authorized.The Medina County Court of Common Pleas initially granted judgment on the pleadings for the defendants, finding Gault’s claim barred by res judicata. The Ninth District Court of Appeals reversed, holding that res judicata did not apply because the total amount owed and the methodology for determining the fees were not ascertainable from the final judgment in the divorce action, and the defendants were not parties to the prior proceedings. On remand, the trial court again ruled for the defendants, interpreting the statutes to permit the clerk to charge two dollars per page—one dollar under R.C. 2303.20(H) and an additional dollar under former R.C. 2303.201(B)(1). The Ninth District reversed, concluding that only one additional dollar total could be charged for the service, not one dollar per page.The Supreme Court of Ohio reviewed the case, consolidating a discretionary appeal and a certified conflict. The court held that, under the plain text of former R.C. 2303.201(B)(1), the clerk may charge only one additional dollar total for making a complete record under R.C. 2303.20(H), regardless of the number of pages. The Supreme Court of Ohio affirmed the judgment of the Ninth District Court of Appeals. View "State ex rel. Gault v. Medina Cty. Court of Common Pleas Clerk" on Justia Law

A private citizen sought to obtain specific health data from the Ohio Department of Health to research the effects of COVID-19 vaccinations. The department maintains databases containing death and vaccination information, which can be exported into spreadsheets using specialized software. The requester initially asked for spreadsheets with over 100 data fields spanning several years, later narrowing the request to a single year and specifying redaction of protected health information. The department denied the request, stating that the records did not exist in the requested format, that fulfilling the request would require creating new records, and that it could not guarantee the protection of private information.After the department’s denial, the requester filed an original action in the Supreme Court of Ohio, seeking a writ of mandamus to compel production of the requested spreadsheets. The department argued that the request would require it to run new queries and generate new files, which it was not obligated to do under Ohio’s Public Records Act. The court admitted rebuttal evidence from the requester, including affidavits addressing whether similar data had previously been provided and the nature of attorney’s fees incurred.The Supreme Court of Ohio held that the department was not required to create new records in response to a public records request. The court reasoned that programming a new query to extract and organize specific information from existing databases constitutes creating a new record, which is beyond the department’s legal obligations. As a result, the court denied the writ of mandamus and the requester’s claims for statutory damages, court costs, and attorney’s fees. View "State ex rel. Huwig v. Dept. of Health" on Justia Law

The case concerns a defendant who was charged with multiple counts of rape and gross sexual imposition involving a minor. He pleaded guilty to several counts, after which his defense counsel withdrew and new counsel was appointed. Despite being represented, the defendant filed several motions on his own, including a motion to withdraw his pleas and a motion to represent himself. The trial court allowed him to represent himself but denied his motion to withdraw his pleas. Before sentencing, he requested and was granted new counsel, and was ultimately sentenced to concurrent prison terms.The defendant appealed to the Ninth District Court of Appeals, arguing, among other things, that the trial court failed to obtain a proper waiver of counsel. The appellate court agreed, finding that the trial court erred in accepting the waiver and failed to comply with procedural requirements, so it reversed and remanded. On remand, the trial court determined that the guilty pleas remained valid and resentenced the defendant. The defendant appealed again, but the appellate court affirmed the trial court’s decision. He then filed an application to reopen his appeal under Ohio Appellate Rule 26(B), claiming ineffective assistance of appellate counsel. The Ninth District granted the application but later confirmed its prior judgment, finding that the defendant had not adequately addressed how his prior appellate counsel was deficient or how he was prejudiced by that deficiency.The Supreme Court of Ohio reviewed whether an appellate court may presume ineffective assistance of counsel in a reopened appeal when the appellant fails to specifically argue counsel’s deficiency and resulting prejudice, as required by App.R. 26(B)(7). The court held that the requirements of App.R. 26(B)(7) are mandatory: an appellant must address both the deficiency of prior appellate counsel and the resulting prejudice in their brief. Because the defendant failed to do so, the Supreme Court of Ohio affirmed the judgment of the Ninth District Court of Appeals. View "State v. Clark" on Justia Law

One Power Company challenged two orders issued by the Public Utilities Commission of Ohio (PUCO) regarding Ohio Power Company’s fifth electric-security plan. The first issue concerned a protective agreement governing access to confidential discovery materials. One Power argued that the agreement unreasonably prevented its chief executive officer and expert witness, an employee, from accessing all discovery, which allegedly disadvantaged its ability to litigate. The second issue involved the commission’s decision to continue a nonbypassable basic-transmission-cost rider, meaning all customers—including those who purchase generation service from competitive suppliers—must pay the charge.After AEP Ohio filed its application for the fifth electric-security plan, One Power intervened and sought broader access to confidential materials. The PUCO’s attorney examiner denied One Power’s motion for a more permissive protective agreement, finding the proposed limits reasonable. One Power’s interlocutory appeal was also denied. At the evidentiary hearing, One Power renewed its objections, but the commission affirmed the examiner’s rulings and later denied rehearing. Regarding the transmission rider, the commission maintained its nonbypassable status, citing the need for further study before making major changes and noting consistency with prior practice. One Power’s rehearing application on this issue was also denied.On appeal, the Supreme Court of Ohio reviewed whether the PUCO’s orders were unlawful or unreasonable. The court held that One Power failed to demonstrate particularized harm from the protective agreement and that the commission acted within its statutory and regulatory authority in continuing the nonbypassable rider. The court found no violation of state electric policy or commission precedent. Accordingly, the Supreme Court of Ohio affirmed the PUCO’s orders. View "In re Application of Ohio Power Co." on Justia Law

Dayton Power and Light Company (DP&L), operating as AES Ohio, sought approval from the Public Utilities Commission of Ohio (PUCO) regarding whether its electric security plan (ESP) resulted in significantly excessive earnings for the years 2018 and 2019. The ESP is a mechanism for setting the standard generation rate for customers who do not choose a competitive supplier. During this period, DP&L also transitioned from its third ESP (ESP III) back to its first ESP (ESP I) after the commission invalidated a similar rider in another utility’s plan, following a decision by the Supreme Court of Ohio. DP&L’s parent company, AES Corporation, made substantial capital contributions to support future investments in grid modernization.PUCO consolidated several related cases and found that DP&L’s ESP resulted in excessive earnings of $3.7 million in 2018 and $57.4 million in 2019. However, PUCO determined that DP&L could offset these excessive earnings with its commitment to future capital investments, and therefore, no refund to consumers was required. PUCO also found that DP&L’s ESP passed the required quadrennial review tests, including a prospective analysis of earnings and a comparison to market-rate offers. The Office of the Ohio Consumers’ Counsel (OCC) appealed, challenging the refusal to order refunds and the continued collection of a rate-stabilization charge. DP&L filed a protective cross-appeal, asserting alternative grounds for affirmance.The Supreme Court of Ohio reviewed the case and held that PUCO was not authorized under R.C. 4928.143(F) to allow DP&L to retain significantly excessive earnings based solely on its commitment to future investments. The court reversed PUCO’s orders and remanded the case for a new significantly excessive earnings test analysis. The court rejected OCC’s challenge to the rate-stabilization charge, finding its legality was not at issue in this appeal, and also rejected DP&L’s alternative grounds for affirmance. View "In re Application of Dayton Power & Light Co." on Justia Law

A divorce and child-custody case between two parents was initially filed in 2019 in the Cuyahoga County Court of Common Pleas, Domestic Relations Division, where a guardian ad litem was appointed for their minor children. The parents made partial payments toward the guardian ad litem’s fees, but a motion for payment of the remaining fees was pending when the mother requested, and the court granted, a dismissal of the case without prejudice. Shortly after, the parents refiled for divorce, and the guardian ad litem sought payment for services rendered in both the dismissed and refiled cases. The trial court ordered both parents to pay their respective shares of the outstanding fees.The father appealed the trial court’s order to the Eighth District Court of Appeals, arguing that the court erred by ordering payment of fees incurred in the dismissed case. The appellate court initially dismissed the appeal for lack of jurisdiction, stating that such an order was interlocutory and not final or appealable. Upon reconsideration, however, the appellate court reversed its position, finding that under the specific circumstances, the order was final and appealable under R.C. 2505.02(B)(2) because it affected a substantial right in a special proceeding. The appellate court then vacated the trial court’s fee order.The Supreme Court of Ohio reviewed the case and held that an interlocutory order requiring payment of guardian ad litem fees in an ongoing divorce and child-custody proceeding is not a final order under R.C. 2505.02(B). The court reasoned that such orders do not, as a category, affect a substantial right requiring immediate appeal, and parties must wait for a final judgment before appealing. Consequently, the Supreme Court of Ohio vacated the judgment of the Eighth District Court of Appeals, finding it lacked jurisdiction to review the fee order. View "E.A.K.M. v. M.A.M." on Justia Law

The case concerns a personal injury lawsuit in which the plaintiffs attempted to serve the defendant with a summons and complaint at an address where he no longer resided. The plaintiffs had previously been informed, during an earlier related lawsuit, that the defendant had moved to a new address. Despite this knowledge, they directed service to the defendant’s former residence, which was then occupied by unrelated tenants. The certified mail was accepted by one of the tenants, who eventually forwarded the documents to the defendant’s father, and the father then delivered them to the defendant. The defendant received the summons only days before his answer was due.After the complaint was refiled, the defendant raised the defense of insufficient service of process in his answer. Nearly two years later, he moved for summary judgment, arguing that service had not been perfected within the required one-year period under Ohio Civil Rule 3(A), since the summons was sent to an outdated address. The Summit County Court of Common Pleas granted summary judgment to the defendant, finding that although the plaintiffs’ service attempt complied with the procedural requirements of Civil Rule 4.1(A)(1)(a), it did not meet the due process standard of being reasonably calculated to provide notice. The Ninth District Court of Appeals affirmed this decision.The Supreme Court of Ohio reviewed the case and held that for service of process to be sufficient, it must not only comply with the procedural rules but also be reasonably calculated to apprise the defendant of the lawsuit, as required by due process. Service to the defendant’s former residence, when the plaintiffs were aware of his current address, was not reasonably calculated to provide notice and was therefore insufficient. The court affirmed the judgment of the Ninth District Court of Appeals. View "Hunt v. Alderman" on Justia Law