Justia Ohio Supreme Court Opinion Summaries

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Jaidee Miree and Desmond Duncan were charged with murder, involuntary manslaughter, felonious assault, and other offenses related to the death of Ramses Hurley on June 16, 2019. The incident occurred during an attempted robbery where Hurley was picked up under the pretense of a drug deal. A struggle ensued, shots were fired, and Hurley was ejected from the moving vehicle, resulting in his death from blunt-force trauma. At trial, conflicting testimonies were presented regarding who initiated the violence and whether Hurley had a gun.The trial commenced in June 2021, and the trial court instructed the jury on self-defense using the preamendment version of R.C. 2901.09, which included a duty to retreat. Miree and Duncan were found guilty of felony murder, felonious assault, and other charges, and were sentenced to 15 years to life in prison. They appealed, arguing that the trial court should have applied the amended version of R.C. 2901.09, effective April 6, 2021, which eliminated the duty to retreat.The Eighth District Court of Appeals upheld the trial court's decision, ruling that the amendment to R.C. 2901.09 was substantive and could not be applied retroactively to offenses committed before its effective date. A dissenting judge argued that the amendment should apply to all trials after its effective date.The Supreme Court of Ohio reviewed the case and affirmed the Eighth District's decision. The court held that the amendment to R.C. 2901.09, which eliminated the duty to retreat, did not apply retroactively to acts of self-defense that occurred before the amendment's effective date. The court concluded that the trial court correctly applied the former version of the statute, and the judgment of the Eighth District Court of Appeals was affirmed. View "State v. Miree" on Justia Law

Posted in: Criminal Law
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Chelsie Kennedy pled guilty to robbery charges in three different cases in the Franklin County Court of Common Pleas. She received an aggregate nine-year sentence in one case, a five-year sentence in another case to be served consecutively to the first, and a six-year sentence in a third case to be served concurrently with the second but consecutively to the first. Kennedy filed motions for judicial release in the latter two cases, arguing she was eligible based on the aggregate of her sentences.The trial court granted Kennedy's motions for judicial release in the two cases, finding her to be an eligible offender under R.C. 2929.20(B) and (C)(4) and (5). The court noted that Kennedy had served more than eight years in prison and considered her conduct in prison and the seriousness and recidivism factors. The court suspended her sentences in the two cases and placed her on community control for three years, to begin after completing her sentence in the first case. The State appealed, arguing that Kennedy had not completed her nine-year sentence in the first case and that judicial release eligibility should be determined separately for each stated prison term.The Supreme Court of Ohio reviewed the case and concluded that judicial-release eligibility is determined separately for each stated prison term, informed by the aggregate of all nonmandatory prison terms imposed. The court found that the lower courts did not conduct a complete inquiry into whether Kennedy had served the requisite amount of her stated prison terms before filing her motion for judicial release. The Supreme Court reversed the judgment of the Tenth District Court of Appeals and remanded the case to the trial court for further proceedings to determine whether Kennedy completed the prescribed waiting period. View "State v. Kennedy" on Justia Law

Posted in: Criminal Law
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Quantez Wilcox met his ex-girlfriend, Doniesha Monroe, near a public library in Cincinnati. During their conversation, Monroe's boyfriend, Keshawn Turner, approached and argued with Monroe. Wilcox, believing Turner was reaching for a gun, shot Turner, who later died. Wilcox fled but was soon stopped and arrested by police. Meanwhile, Monroe identified Wilcox as the shooter to a police officer, whose body camera recorded the interaction. Monroe also mentioned past bad acts by Wilcox after learning he was apprehended.The trial court admitted the body-camera footage into evidence despite Wilcox's objection, arguing it violated his right to confrontation since Monroe did not testify in court. Wilcox was convicted of multiple felonies, including murder. The First District Court of Appeals affirmed some convictions but reversed the murder conviction, ruling that Monroe's statements were testimonial and their admission violated Wilcox's confrontation rights. The court ordered a new trial for the murder charge.The Supreme Court of Ohio reviewed whether the admission of Monroe's statements violated Wilcox's confrontation rights. The court determined that Monroe's initial statements were nontestimonial as they were made during an ongoing emergency. However, statements made after Wilcox's apprehension were testimonial. The court reversed the First District's decision regarding the initial statements and remanded the case to determine their admissibility under the Ohio Rules of Evidence and to conduct a harmless-error analysis. View "State v. Wilcox" on Justia Law

Posted in: Criminal Law
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In this case, the defendant, Garry Smith, was indicted on two counts of domestic violence for an incident on March 21, 2020, involving his pregnant fiancée, B.B. Smith pleaded not guilty and filed a motion to exclude B.B.'s statements recorded on police body cameras, arguing it would violate his right to confrontation. The trial court initially denied the motion but reserved its final ruling. During the bench trial, B.B. did not appear, and the State presented evidence including body-camera footage capturing B.B.'s statements to police and EMTs.The trial court admitted the body-camera footage, ruling B.B.'s statements were nontestimonial and fell under the excited utterance hearsay exception. Smith was found guilty and sentenced accordingly. On appeal, the Eighth District Court of Appeals reversed the trial court's decision, finding that B.B.'s statements to the police were testimonial and their admission violated Smith's confrontation rights. The appellate court did not address Smith's hearsay challenge or the weight of the evidence due to its dispositive ruling on the confrontation issue.The Supreme Court of Ohio reviewed the case to determine if the admission of B.B.'s statements violated Smith's confrontation rights. The court held that B.B.'s statements to the police officer were testimonial because they were made to further the officer's investigation of a past crime, not to address an ongoing emergency. However, B.B.'s statements to the EMTs were deemed nontestimonial as they were made for the purpose of receiving medical care.The Supreme Court of Ohio reversed the appellate court's judgment regarding Smith's convictions for the March 21, 2020 incident and remanded the case to the Eighth District to determine the admissibility of B.B.'s statements to the EMTs under hearsay rules, conduct a harmless-error analysis, and address Smith's remaining assignments of error as necessary. View "State v. Smith" on Justia Law

Posted in: Criminal Law
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A defendant was tried for shooting at a group of four people and was found guilty by a jury of four counts of felonious assault, each with a firearm specification, one count of discharging a firearm on or near prohibited premises with a firearm specification, and one count of improperly handling firearms in a motor vehicle. The trial court imposed three-year prison terms for each of the four firearm specifications attached to the felonious assault charges, with two terms being mandatory and two discretionary. All four terms were ordered to be served consecutively, resulting in a total of 12 years for the firearm specifications. Additional prison terms for the underlying offenses were ordered to be served concurrently, leading to an aggregate prison term of 16 to 18 years.The defendant appealed to the Twelfth District Court of Appeals, arguing that only two of the four firearm specification prison terms should run consecutively. The appellate court upheld the trial court's decision, interpreting the relevant statutes to require consecutive service of all four prison terms for the firearm specifications.The Supreme Court of Ohio reviewed the case and determined that the trial court erred in running the two discretionary prison terms for the firearm specifications consecutively. The court held that under R.C. 2929.41(A) and 2929.14(C)(1), only mandatory prison terms for firearm specifications must be served consecutively, while discretionary terms must be served concurrently unless an exception applies. The court reversed the appellate court's judgment and remanded the case to the trial court with instructions to amend the sentence to run the two discretionary prison terms concurrently with each other and with the other prison terms imposed. View "State v. Beatty" on Justia Law

Posted in: Criminal Law
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In 2014, a father was convicted of felonious assault and child endangering after his infant son was found with 26 bone fractures. The state’s case relied heavily on a medical expert who used a process-of-elimination methodology to conclude that the father intentionally caused the injuries, as no nontraumatic medical cause was identified. The expert made several assertions about medical principles, including the impact of Vitamin D on bone health, which were used to rebut the father's defense.The trial court denied the father's motion for leave to file a motion for a new trial without holding a hearing. The Ninth District Court of Appeals affirmed this decision, noting that the expert opinions presented by the father were known at the time of the trial and that the new studies merely confirmed existing theories.The Supreme Court of Ohio reviewed the case and focused on whether the new scientific studies presented by the father constituted newly discovered evidence under Crim.R. 33(A)(6). The court noted that significant changes in scientific understanding could qualify as newly discovered evidence, even if based on theories known at the time of the trial. The court emphasized that new scientific evidence must provide a significantly stronger argument for the defense to warrant a new trial.The Supreme Court of Ohio held that the trial court abused its discretion by not holding a hearing on the father's motion for leave. The court reversed the appellate court's decision and remanded the case to the trial court to hold a hearing on the motion for leave to file a motion for a new trial. View "State v. Grad" on Justia Law

Posted in: Criminal Law
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Clifford J. Culgan requested unredacted public records related to Jefferson County Grand Jury Final Reports for October 1997, November 1997, December 1997, and January 1998 from the Jefferson County Clerk of Courts. The Deputy Clerk, Christianne Benton, responded by providing the requested records but redacted the names of the grand jurors, the signature of the grand jury foreperson, and information on expunged cases using Wite-Out. Culgan claimed he did not receive the response and filed a mandamus action seeking the unredacted records, statutory damages, and court costs.The Supreme Court of Ohio reviewed the case. The clerk argued that the redactions were justified under state law, specifically citing State ex rel. Beacon Journal Pub. Co. v. Bond. The court found that the clerk's redactions of case information for expunged cases were proper but determined that the names of the grand jurors and the signature of the grand jury foreperson should not have been redacted. The court also found that the clerk's use of Wite-Out for redactions was permissible and that the redactions were plainly visible.The Supreme Court of Ohio granted a writ of mandamus ordering the clerk to provide the grand jury reports without redacting the grand jurors' names or the foreperson's signature. However, the court denied the writ regarding the redacted case information, as those redactions were deemed appropriate. The court also denied Culgan's requests for statutory damages and court costs, concluding that the clerk reasonably believed the redactions were proper based on existing case law. View "State ex rel. Culgan v. Jefferson Cty. Clerk of Courts" on Justia Law

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Niv Goomai and Bar Hajbi purchased a property in Cincinnati and contracted with H&E Enterprise, L.L.C., Ohad Investment Group, and Avi Ohad for renovations. The renovations were not completed, leading Goomai to sell the property. Goomai then sued the defendants for breach of contract, violation of the Deceptive Trade Practices Act, and fraudulent misrepresentation, seeking actual damages but not injunctive relief.A jury trial was held before a magistrate, where the jury found that H&E had breached its contract and awarded Goomai $30,604.09 in damages. The jury also found that H&E and Ohad had engaged in deceptive trade practices but awarded $0 in damages for this violation. The jury ruled in favor of the defendants on the fraudulent misrepresentation claim. Goomai subsequently filed a motion for attorney’s fees and costs, which the magistrate denied, reasoning that Goomai did not qualify as a prevailing party under the Deceptive Trade Practices Act since they did not obtain any relief on the merits of their claim. The trial court adopted the magistrate’s decision, and Goomai appealed.The First District Court of Appeals reversed the trial court’s decision, holding that a prevailing party under the Deceptive Trade Practices Act is one who obtains a judgment in their favor, regardless of whether they received a remedy. The court remanded the case to the trial court to determine the amount of attorney’s fees to which Goomai was entitled.The Supreme Court of Ohio reviewed the case and concluded that to be a prevailing party under the Deceptive Trade Practices Act, a plaintiff must obtain actual damages or injunctive relief. Since Goomai did not receive any monetary damages or injunctive relief, they were not considered prevailing parties. The Supreme Court of Ohio reversed the judgment of the First District Court of Appeals and reinstated the trial court’s judgment denying attorney’s fees. View "Goomai v. H&E Enterprise, L.L.C." on Justia Law

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Paul Prinkey Jr. was injured while working for Emerine’s Towing, Inc. on January 19, 2015. His workers' compensation claim was allowed for myocardial infarction, substantial aggravation of pre-existing coronary artery disease, and major depressive disorder. Prinkey filed his first application for permanent-total-disability (PTD) compensation on February 4, 2019, which was denied by the Industrial Commission of Ohio based on medical evaluations indicating he was capable of sedentary work. Prinkey filed a second application for PTD compensation on June 4, 2021, citing worsening symptoms.The Industrial Commission denied Prinkey’s second application, stating he failed to present evidence of new and changed circumstances as required by the amended R.C. 4123.58(G). The commission's staff hearing officer (SHO) found no jurisdiction to address the application due to the lack of new evidence. Prinkey sought a writ of mandamus from the Tenth District Court of Appeals, which returned the matter to the commission for further proceedings, finding the SHO's order lacked adequate explanation and evidence.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District's decision. The court held that the SHO failed to comply with the requirements of State ex rel. Noll v. Indus. Comm., which mandates that the commission must specifically state the evidence relied upon and briefly explain the reasoning for its decision. The court found that the SHO did not provide sufficient reasoning or cite specific evidence to support the conclusion that Prinkey failed to present new and changed circumstances. Consequently, the case was returned to the Industrial Commission for further proceedings. View "State ex rel. Prinkey v. Emerine's Towing, Inc." on Justia Law

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In July 2016, Michael Riley was indicted in the Cuyahoga County Common Pleas Court for multiple charges, including aggravated murder and felonious assault, stemming from a shooting incident in Cleveland. Riley waived his right to a jury trial, and the trial court found him not guilty of aggravated murder but guilty of the remaining charges under a complicity theory, sentencing him to 26 years to life in prison. Riley's convictions were affirmed on direct appeal by the Eighth District Court of Appeals, and his motion for leave to file a delayed appeal was denied by the Supreme Court of Ohio.In October 2022, Riley filed an application for postconviction DNA testing of six shell casings found at the crime scene, arguing that advancements in DNA technology could yield new results. The State opposed the application, noting that the initial DNA testing had consumed the swabs and that Riley had not demonstrated any technological advancements that would change the outcome. The trial court summarily denied Riley's application without explanation, and later adopted the State's proposed findings of fact and conclusions of law verbatim.The Eighth District Court of Appeals affirmed the trial court's judgment, stating that the trial court corrected its initial error by issuing findings of fact and conclusions of law. However, the Supreme Court of Ohio found that the trial court did not engage in the required independent analysis and merely rubberstamped the State's proposed findings. The Supreme Court reversed the judgment of the Eighth District Court of Appeals and remanded the case to the trial court to independently consider Riley's application for postconviction DNA testing and provide reasons for its decision as required by R.C. 2953.73(D). View "State v. Riley" on Justia Law

Posted in: Criminal Law