Justia Ohio Supreme Court Opinion Summaries

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

A city filed a criminal complaint against a property owner, alleging that his property was in violation of certain provisions of the International Property Maintenance Code (IPMC), which the city had adopted by ordinance. The complaint stated that the property’s residence lacked water service, had holes in the roof, and that a break wall was collapsing into a river. It also alleged the presence of various items described as “debris,” such as barrels, lawn mowers, boats, trailers, propane tanks, and overgrown vegetation. The city claimed these conditions violated IPMC sections requiring properties to be maintained in a “clean,” “safe,” and “sanitary” condition.The property owner moved to dismiss the charges in the Huron Municipal Court, arguing that the IPMC provisions were unconstitutionally vague because the terms “clean,” “safe,” and “sanitary” were undefined. The trial court agreed, relying on a prior decision from the Seventh District Court of Appeals, State v. ACV Realty, which had found similar IPMC language void for vagueness. As a result, the trial court dismissed the relevant counts. The city appealed, and the Sixth District Court of Appeals reversed, holding that the terms in question should be given their ordinary meanings and were sufficiently clear to inform property owners of the prohibited conduct.The Supreme Court of Ohio reviewed the case to resolve a conflict between appellate districts. The court held that a defendant cannot successfully challenge a law as void for vagueness if his conduct clearly falls within the activities the law prohibits. Because the alleged conditions of the property—such as lack of water, structural decay, and accumulation of debris—clearly violated the IPMC provisions, the property owner’s vagueness challenge failed. The Supreme Court of Ohio affirmed the appellate court’s judgment and remanded the case to the municipal court for further proceedings. View "Huron v. Kisil" on Justia Law

A business owner, who held a 50% stake in a group of skilled-nursing and real estate companies, personally guaranteed a $77 million loan arranged by a bank for those companies and others managed by his business partner. The loan was part of a refinancing effort after the companies’ prior lender declared a default. The owner signed both an initial guaranty agreement and a subsequent reaffirmation of that guaranty. Within a year, the companies defaulted on the new loan, and it was later revealed that the business partner had engaged in fraudulent check-kiting. The bank demanded repayment from the guarantors, including the owner, who then argued that he had been fraudulently induced into signing the guaranty because the bank failed to disclose material financial risks related to his partner and the companies.The Hamilton County Court of Common Pleas granted summary judgment to the bank, finding that the owner had waived defenses under the guaranty agreement, that the bank owed no duty to disclose information about the companies’ financial condition, and that the owner could not establish fraudulent inducement. On appeal, the First District Court of Appeals reversed, holding that as a surety, the owner could assert a defense based on the bank’s alleged failure to disclose facts that materially increased his risk, adopting the “doctrine of increased risk” from Section 124(1) of the Restatement (First) of Security.The Supreme Court of Ohio reviewed the case and reversed the appellate court’s decision. The court held that, under Ohio law, parties to an arm’s-length transaction do not owe each other a duty to disclose unknown facts that materially increase risk, unless a special relationship of trust or confidence exists. This rule applies regardless of whether one party is a guarantor or surety. The court reinstated the trial court’s grant of summary judgment in favor of the bank. View "Huntington Natl. Bank v. Schneider" on Justia Law

The case concerns an individual who pleaded guilty in 2004 to two counts of forgery, both fifth-degree felonies, after depositing counterfeit checks and withdrawing funds from a credit union. The trial court sentenced him to concurrent nine-month prison terms and ordered him to pay $2,663 in restitution to the victim, Mid-State Credit Union, and $408 in court costs. The sentencing entry specified that these amounts were entered as civil judgments. After serving his sentence and completing postrelease control, the individual applied in 2022 to have the record of his convictions sealed, though he had not paid the restitution.The Franklin County Court of Common Pleas granted the application to seal the records, despite the State’s objection that restitution remained unpaid. The State appealed, but the Tenth District Court of Appeals affirmed the trial court’s decision. The appellate court reasoned that because the restitution was entered “as a civil judgment,” it was not a criminal sanction that needed to be satisfied before the record could be sealed. The court further concluded that the civil judgment for restitution had become permanently dormant under debtor-protection laws, as it had not been revived within the statutory period.The Supreme Court of Ohio reviewed the case and held that, regardless of how a restitution order is labeled in a sentencing entry, it remains a criminal sanction that is part of the sentence. Therefore, restitution must be paid before an offender is eligible to apply to have the record of conviction sealed. The court reversed the judgment of the Tenth District Court of Appeals and remanded the case for consideration of the individual’s constitutional arguments. View "State v. T.W.C." on Justia Law

In 1996, the defendant pleaded guilty to several first-degree felonies, including rape, attempted aggravated murder, kidnapping, and aggravated burglary, for acts committed in 1995. The trial court imposed an aggregate indefinite prison sentence of 15 to 50 years under the sentencing laws in effect before July 1, 1996. Over the years, the defendant challenged aspects of his sentence and conviction, including the indefinite nature of his sentence and the lack of eligibility for judicial release, but these challenges were unsuccessful.After serving more than 26 years, the defendant filed a motion for judicial release under R.C. 2929.20 in December 2021, arguing that he was serving a “stated prison term” and had completed the mandatory portion of his sentence. The State of Ohio opposed the motion, asserting that the defendant was serving an indefinite sentence under pre-S.B. 2 law and was therefore ineligible for judicial release. The trial court granted the motion for judicial release, placing the defendant on community control, and the State appealed. The Seventh District Court of Appeals affirmed, reasoning that amendments to R.C. 2929.20 had expanded eligibility for judicial release to include offenders serving nonmandatory sentences on or after April 7, 2009.The Supreme Court of Ohio reviewed the case and held that the definition of “eligible offender” for purposes of judicial release under R.C. 2929.20 includes only those serving a “stated prison term,” as defined in R.C. 2929.01. The court concluded that an offender serving an indefinite sentence imposed under pre-S.B. 2 law does not meet this definition and is therefore not eligible for judicial release. The Supreme Court of Ohio reversed the judgment of the Seventh District Court of Appeals and remanded the case to the trial court to deny judicial release. View "State v. Staffrey" on Justia Law

A company leased 24 properties from a landlord under separate agreements that included options to renew the leases for additional terms, provided the tenant gave written notice 120 days before expiration. The tenant successfully renewed twice, but in 2021, failed to send the required renewal notice to the landlord by the deadline. The landlord notified the tenant that the leases would terminate, and after unsuccessful negotiations for new leases, the tenant sought a court declaration that its late renewal was still effective, citing the significant value of improvements made to the properties.The Franklin County Court of Common Pleas ruled in favor of the tenant, finding that equity could forgive the tenant’s “honest mistake” in missing the deadline and prevent forfeiture of the improvements. The court also found that the landlord’s acceptance of rent after the expiration of a tolling agreement estopped the landlord from terminating the leases. The Tenth District Court of Appeals affirmed, relying on prior Ohio appellate decisions that allowed equitable relief for honest mistakes or even negligence if forfeiture would result and the landlord was not prejudiced.The Supreme Court of Ohio reviewed the case and reversed the Tenth District’s judgment. The court held that while equity may excuse a failure to comply with a lease renewal option in cases of fraud, accident, or mistake, it does not extend to negligence. The court clarified that “mistake” refers to a misapprehension of a basic assumption at contract formation, not a negligent failure to act. Because the tenant’s failure to timely exercise the renewal option was due to negligence, equitable relief was not warranted. The case was remanded to the Tenth District Court of Appeals to consider the landlord’s remaining arguments regarding equitable estoppel. View "Ashland Global Holdings, Inc. v. SuperAsh Remainderman, Ltd. Partnership" on Justia Law

A limited partnership operating a timber farm in Monroe County, Ohio, purchased a Mercedes-Benz Geländewagen in 2018 for use on its rugged, 1,100-acre property, which is primarily forested. The farm, with a history dating back to 1902, had transitioned from fruit and dairy to timber production. The vehicle was acquired to facilitate forest management activities, including traversing difficult terrain to apply chemicals and equipment for the removal of invasive species, inspect timber, and support sustainable harvesting practices. The farm had not reported timber sales or income since 2011, but had invested in forest management and hired consultants to implement long-term plans for sustainable timber production.The Ohio Tax Commissioner issued a use-tax assessment on the vehicle, finding that the farm was not actively engaged in the business of farming due to the absence of recent sales or income, and that the vehicle was not used directly or primarily in farming activities. The Board of Tax Appeals affirmed the assessment, concluding that the vehicle was used mainly for transportation around the property rather than for direct farming purposes, and that the farm had not demonstrated the vehicle’s primary use was for farming.The Supreme Court of Ohio reviewed the case and reversed the Board of Tax Appeals’ decision. The court held that the statutory exemption for use tax on items used in farming does not require “direct” use, and that the farm’s activities—including forest management and preparation for future timber sales—constituted engagement in the business of farming. The court found that the vehicle was used in farming and primarily for that purpose, based on uncontradicted testimony. The case was remanded for cancellation of the tax assessment. View "Claugus Family Farm, L.P. v. Harris" on Justia Law

A company constructed and operated a large interstate natural gas pipeline running through Ohio, which was completed in late 2018. The project’s actual construction costs significantly exceeded initial estimates due to unusually heavy rainfall causing delays and an environmental incident that led to regulatory actions and further delays. During construction, an investment firm acquired a substantial indirect ownership interest in the pipeline’s parent company, paying a price that implied a high valuation for the pipeline.For the 2019 tax year, the Ohio Tax Commissioner assessed the taxable value of the Ohio portion of the pipeline using a statutory cost-based method, resulting in a valuation that the company believed was excessive. The company challenged the assessment, arguing that the pipeline’s true value was much lower, citing alternative appraisal methods and the impact of construction delays and overruns. The Tax Commissioner rejected these arguments, maintaining that the statutory method produced the correct value.The company appealed to the Ohio Board of Tax Appeals, where both parties presented expert appraisals. The company’s appraiser used a unit appraisal approach and arrived at a lower value, while the Tax Commissioner’s appraiser, using both cost and income approaches, opined a higher value. The Board found the Tax Commissioner’s appraisal more credible, especially in light of the investment firm’s transaction and the actual construction costs, and ordered the pipeline to be valued according to that appraisal.On further appeal, the Supreme Court of Ohio reviewed whether the Board’s decision was reasonable and lawful. The court held that the Board has broad discretion in weighing competing appraisals and evidence, and that its adoption of the Tax Commissioner’s appraisal was supported by the record. The court affirmed the Board’s decision, upholding the higher valuation for tax purposes. View "Rover Pipeline, L.L.C. v. Harris" on Justia Law

A man who had attended elementary school with a woman, but had never been friends or even acquaintances with her, began contacting her more than a decade later. The woman, A.P., posted on her public Instagram account for her 29th birthday, and the man, Dorian Crawl, commented with a “sad emoji” and a message expressing affection and a desire to meet. A.P. did not respond. Days later, Crawl commented again on another post, asking if the video showed her house. Less than a month after these online interactions, Crawl appeared uninvited at A.P.’s apartment, knocked on her door, identified himself as her “friend,” and turned the doorknob. A.P., frightened, locked the door, hid her daughter, and called the police. Crawl later admitted to police that he had found A.P.’s address online and continued to message her even after being confronted by law enforcement. A.P. testified that these events caused her significant anxiety and changes to her daily life.The Miamisburg Municipal Court found Crawl guilty of menacing by stalking under R.C. 2903.211(A)(1). On appeal, the Second District Court of Appeals affirmed the conviction, holding that Crawl’s pattern of conduct—including the social media messages and the uninvited visit—along with A.P.’s testimony about her mental distress, was sufficient to support the conviction.The Supreme Court of Ohio reviewed the case and affirmed the judgment of the Second District Court of Appeals. The court held that, when viewing the evidence in the light most favorable to the prosecution, a rational trier of fact could find that the essential elements of menacing by stalking were proven beyond a reasonable doubt. The court clarified that explicit threats, a prior relationship, or notice from the victim are not required to establish the offense. The court concluded that Crawl’s actions constituted a pattern of conduct, caused mental distress, and were done knowingly. View "State v. Crawl" on Justia Law