Justia Ohio Supreme Court Opinion Summaries

In this case, the Supreme Court of Ohio was called upon to interpret the definition of "motor vehicle" as it applied to the crime of aggravated vehicular assault. The defendant, Joshua Fork, was charged with multiple counts, including aggravated vehicular assault, after driving a Polaris under the influence of alcohol and injuring his passengers. At issue was whether the Polaris should be classified as a "motor vehicle" or a "utility vehicle."The Court ruled that the definition of "motor vehicle" in R.C. 4501.01(B), which applies to penal laws, should be used in the context of aggravated vehicular assault. It also held that the Polaris should be classified as a "utility vehicle," as defined by R.C. 4501.01(VV), based on its principal purpose, not its use at the time of the incident.The Court reasoned that the principal purpose of the Polaris, as shown by evidence and testimony, was for farm-related activities, such as hauling rocks and bags of seed, removing limbs, pulling a sprayer, and trimming trees. The Polaris's ancillary use for recreation did not affect its principal purpose.The Court concluded that, since the Polaris fit the definition of a "utility vehicle" under R.C. 4501.01(VV), the evidence admitted at trial was legally insufficient to support Fork’s convictions for aggravated vehicular assault. Consequently, the Court affirmed the judgment of the Sixth District Court of Appeals, which had reversed the trial court's judgment and vacated Fork’s convictions for aggravated vehicular assault. View "State v. Fork" on Justia Law

In the case before the Supreme Court of Ohio, the relator, Kimani Ware, an inmate, sought a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction (“ODRC”), Trumbull Correctional Institution (“TCI”), and several of its employees, to respond to six of his public-records requests, and to award him statutory damages and court costs.Concerning each of the six requests, the respondents argued that they were not required to provide the requested records because Ware did not identify them as formal public-records requests. The court disagreed, stating that the Public Records Act does not require a requester to formally label a request as a “formal public records request”.Regarding the May 29, 2021 and October 6, 2021 requests, the court denied Ware's writ and the request for statutory damages, as the respondents had provided evidence that they provided the requested records. However, for the June 3, 2022 and June 19, 2022 requests, the court granted the writ and awarded Ware $1,000 in statutory damages for each request, as the respondents did not provide the requested documents.As for the June 5, 2022 and July 23, 2022 requests, the writ and the request for statutory damages were denied since Ware did not submit these two requests to the proper records custodians.Lastly, the court denied respondents’ motion to declare Ware a vexatious litigator, stating that respondents had not shown that Ware has “habitually, persistently, and without reasonable cause engage[d] in frivolous conduct". View "State ex rel. Ware v. Ohio Dept. of Rehab. & Corr." on Justia Law

Thomas E. Knuff Jr. was convicted on two counts of aggravated murder with death specifications for killing John Mann and Regina Capobianco. Knuff was released from prison and arranged to stay with Mann. After his release, he began staying at a motel, paid for by a former prison employee, Alicia Stoner, with whom he had a relationship while incarcerated. When his parole officer discovered he was not living at the motel as he claimed, he moved in with Mann. Mann was not living alone; Regina Capobianco also lived there. Knuff and Capobianco had a complicated relationship, and conflict arose between them, which led to the murders.The Supreme Court of Ohio affirmed Knuff's convictions and the imposition of the death sentences, finding that none of the 24 arguments that he presented justified a reversal. Among other things, the court found that the trial court did not err in denying Knuff’s motion for self-representation, which was made just eight days before jury selection began. The court also rejected Knuff’s claim that the trial court improperly restricted his counsel’s voir dire questioning, thereby denying him a meaningful, constitutionally adequate voir dire. The court additionally found that the trial court did not err in overruling Knuff’s challenges for cause of various jurors, or in granting the prosecution's for-cause challenges.The court also found that the trial court's error in giving the jury a duty-to-retreat instruction was harmless beyond a reasonable doubt. The court rejected Knuff’s claim that the jury’s finding of guilt for the aggravated-murder counts, felony-murder specifications, and underlying felony offenses was based on insufficient evidence and that his convictions for those offenses were against the manifest weight of the evidence. View "State v. Knuff" on Justia Law

In this case, Robert Plaza, a prisoner serving an indeterminate sentence, appealed the dismissal of his petition for a writ of habeas corpus by the Ninth District Court of Appeals. Plaza's petition related to the Adult Parole Authority's decision to revoke his parole. He argued that he was denied a preliminary hearing to determine if there was probable cause to believe he had violated parole conditions, that he was denied due process of law, and that he should be immediately released.The Court of Appeals dismissed the petition based on territorial jurisdiction, as Plaza had been moved to a different correctional institution outside of its jurisdiction during the proceedings. However, Plaza argued that he had been transferred back to the original jurisdiction before the dismissal of his petition, and therefore, the Court of Appeals had erred.The Supreme Court of Ohio agreed with Plaza that the dismissal based on territorial jurisdiction was incorrect. However, the court found that Plaza's allegations did not state a claim cognizable in habeas corpus. The court noted that habeas corpus is a remedy for a due-process violation only in extreme circumstances involving unreasonable delay, which was not alleged by Plaza. The court stated that the usual remedy for such a violation is a writ of mandamus compelling a second hearing, not a release from custody. Therefore, the court affirmed the dismissal of Plaza's petition on alternative grounds. View "Plaza v. Black" on Justia Law

This case originates from the Supreme Court of Ohio and concerns a defendant, Tyler Wilson, who was charged with attempted murder and felonious assault. The charges stemmed from an altercation at a gas station where Wilson fired a gun out his car window to scare off the other party involved in the dispute. Wilson claimed he acted in self-defense, but the trial court determined that he was not entitled to a self-defense jury instruction because he did not intend to harm or kill the other party. Wilson was found guilty of felonious assault, but not attempted murder.On appeal, the Supreme Court of Ohio reversed the lower court’s decision, ruling that an individual does not need to intend to harm or kill another person to be entitled to a self-defense jury instruction in a criminal trial. The court found that Wilson’s testimony supported the intent element for self-defense and that his trial counsel was ineffective by failing to request a self-defense jury instruction. As such, the court vacated Wilson’s conviction and remanded the case back to the trial court for further proceedings. View "State v. Wilson" on Justia Law

In this case, the Supreme Court of Ohio addressed the issue of the filing deadline for a petition for postconviction relief following a delayed appeal. The defendant was convicted of murder and other crimes, did not file a direct appeal within the required 30 days but later filed a motion for a delayed appeal, which was granted. He filed a petition for postconviction relief within 365 days of the trial transcript being filed in the court of appeals.The court of appeals had affirmed the trial court's judgment, asserting that the defendant's petition was untimely. They argued that in the case of a delayed appeal, the applicable deadline was not the direct-appeal deadline of 365 days from the date of the filing of the trial transcript but rather the no-appeal-taken deadline of 365 days from the expiration of the time for filing a direct appeal.The Supreme Court of Ohio disagreed, holding that under Ohio law, a delayed appeal of a conviction is a direct appeal, and the same postconviction-relief deadline applies for a delayed appeal as applies to any other type of direct appeal. The court found that the defendant had timely filed his postconviction petition within 365 days after the transcript was filed in the court of appeals in his delayed appeal. Therefore, the Supreme Court of Ohio reversed the judgment of the Eighth District Court of Appeals and remanded the matter to that court for further consideration. View "State v. Dudas" on Justia Law

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