Justia Ohio Supreme Court Opinion Summaries

After a jury trial, Appellee was convicted of one count of rape and one count of kidnapping. The court of appeals vacated both convictions, holding that the State failed to present sufficient evidence showing Appellee knew or had reason to know that the alleged victim's ability to consent was substantially impaired. Upon his release, Appellee filed an action for declaratory judgment seeking compensation from the State for wrongful imprisonment. The trial court granted Appellee's motion for summary judgment, finding that Appellee was innocent of the charges upon which he was convicted, or that no crime was committed by Appellee, or both. The court of appeals affirmed. The Supreme Court reversed, holding (1) one who claims to be a "wrongfully imprisoned individual" under Ohio Rev. Code 2743.48 must prove all of the factors in section 2743.48(A) by a preponderance of the evidence before seeking compensation from the State for wrongful imprisonment; and (2) a trial court adjudicating proof of innocence pursuant to section 2743.48(A)(5) may not find that a claimant has been wrongfully imprisoned based solely on an appellee court judgment vacating a felony conviction due to insufficient evidence and discharging the prisoner without a remand for a new trial. Remanded. View "Doss v. State" on Justia Law

In this appeal of a real-property-valuation case, the city school district board of education challenged a decision of the board of tax appeals (BTA) that affirmed the county board of revision's (BOR) adoption of a sale price as the value of the property at issue for tax year 2007. The school board argued in part that the BOR lacked jurisdiction because the valuation complaint had been signed and submitted by the property owner's spouse, who was not a lawyer. The Supreme Court affirmed the BTA's decision, holding (1) the filing of a valuation complaint by the owner's spouse validly invokes the BOR's jurisdiction; and (2) the record furnished a sufficient basis to support the BTA's finding. View "Columbus City Sch. Dist. Bd. of Educ. v. Franklin County Bd. of Revision" on Justia Law

When a complaint has been filed that contests the county auditor's valuation of a particular parcel, as it was in this case, and when that complaint asks for a value increase or reduction of $17,500 or more, Ohio Rev. Code 5715.19(B) requires that the auditor give notice of the complaint within thirty days of the last day for filing valuation complaints. At issue in this appeal was whether that notification is a prerequisite to the exercise of jurisdiction by the board of revision, and if so, whether the thirty-day deadline itself is jurisdictional. The Supreme Court held (1) under section 5715.19(B), the notification itself is jurisdictional, but the thirty-day requirement is not; and (2) thus, the original failure of the auditor in this case to give notice was cured when the notice was later given after remand by the court of common pleas. Because the court of appeals held the contrary, the Court reversed its decision. View "2200 Carnegie, LLC v. Cuyahoga County Bd. of Revision" on Justia Law

Defendant appealed from a judgment of the court of appeals that affirmed his classification as a Tier I sex offender based on his guilty plea to one count of sexual imposition. At issue was whether the trial court retained authority to classify Defendant as a Teir I sex offender more than a year after the entry of a final judgment of conviction for a sexually oriented offense. The Supreme Court reversed, holding that the trial court lacked authority to reopen this case to reconsider the final judgment it had entered, and the protections against double jeopardy barred it from classifying Defendant as a Tier I sex offender more than a year after it imposed sentence. View "State v. Raber" on Justia Law

This was an original action by Relators, property owners, for a writ of mandamus to compel Respondents, the Department of Natural Resources and its director, to initiate appropriation proceedings for the physical taking of their property resulting from flooding caused by a spillway constructed by Respondents and the state's lake-level-management practices. On December 1, 2011, the court granted a writ of mandamus to compel Respondents to commence appropriation proceedings to determine the amount of their taking of the property. Following failed settlement negotiations, the State filed appropriation cases for the property of two of the relators. All of the relators with the exception of the two then filed a motion for an order for Respondents to show cause why they should not be held in contempt of the court's December 1, 2011 writ. The Supreme Court held that Relators established by clear and convincing evidence that Respondents were in contempt of the court's December 1, 2011 writ and ordered Respondents to file appropriation cases for Respondents' parcels. View "State ex rel. Doner v. Zehringer" on Justia Law

This appeal presented issues regarding the scope of a workers' compensation appeal in common pleas court pursuant to Ohio Rev. Code 4123.512. Specifically, the appeal concerned whether, in that proceeding to determine a claimant's right to participate in the workers' compensation fund, the court was limited to considering those issues that were specifically determined by the Industrial Commission below, or whether the de novo nature of the proceeding obligated the claimant to present and the court to consider all the evidence necessary for determining the claimant's right to participate. The court of appeals rejected the claimant's claim that the trial court erred in placing the burden on him to establish any injury-relatedness or causation in his section 4123.512 appeal because those issues were not considered in the administrative rulings. The Supreme Court affirmed the judgment of the court of appeals, holding that the de novo nature of a section 4123.512 appeal proceeding puts in issue all elements of a claimant's right to participate in the workers' compensation fund. View "Bennett v. Adm'r, Bureau of Workers Comp." on Justia Law

A grand jury issued an indictment charging Appellee with two counts of trafficking in drugs. Appellee filed a motion to dismiss, alleging that the indictment did not sufficiently charge the two trafficking counts because neither count named the specific controlled substance involved. The trial court denied Appellee's motion, and Appellee pleaded no contest to the charges. Appellee appealed, and the court of appeals reversed, holding that the indictment was insufficient because it stated that the drug involved was a Schedule I or II drug instead of naming the specific drug involved. The Supreme Court reversed, holding (1) an indictment charging a defendant with trafficking in drugs under Ohio Rev. Code 2925.03 is sufficient if it names the schedule in which the drug appears; and (2) therefore, the indictment in this case adequately informed Defendant of the charges pending against him. View "State v. Jackson" on Justia Law

At issue in this case was whether, in general, cell-phone records produced by a cell-phone company constitute testimonial evidence that implicates a defendant's right to cross-examine a witness under the Confrontation Clause of the Sixth Amendment. Defendant here was convicted of murder, kidnapping, aggravated robbery, and aggravated burglary. Defendant appealed, arguing that the trial court had erred by allowing cell phone records to be admitted into evidence without being properly authenticated in violation of the Confrontation Clause. The appellate court determined that the admission of the cell-phone records did not contribute to Defendant's conviction and affirmed the judgment of the trial court. The Supreme Court affirmed, holding (1) because cell-phone records are generally business records that are not prepared for litigation and are thus not testimonial, the Confrontation Clause does not affect their admissibility; (2) however, the hearsay rule barred the records' admission in this case because they were not properly authenticated; but (3) the admission of the cell-phone records did not contribute to Defendant's conviction, and their admission was harmless beyond a reasonable doubt. View "State v. Hood" on Justia Law

In this certified conflict, the Supreme Court considered whether a trial court's failure to impose the statutorily mandated fine required by Ohio Rev. Code 2925.11(E)(1)(a) and 2929.18(B)(1) when no affidavit of indigency has been filed with the court prior to the trial court's journal entry of sentencing renders void the part of the sentence waiving the fine. The Supreme Court affirmed the judgment of the court of appeals in resolving the certified conflict, holding that a trial court's failure to impose the required fine under these circumstances renders void the part of the sentence waiving the fine, and that resentencing of the offender is limited to the imposition of the mandatory fine. View "State v. Moore" on Justia Law

In this appeal, the Supreme Court resolved a conflict between decisions of the Ninth District Court of Appeals and the Second District Court of Appeals concerning the effect of an individual retirement account custodian's filing of an interpleader action against competing claimants. The Court held that when the custodian of an individual retirement account filed an interpleader action against the parties claiming to be the beneficiaries of the account, the custodian waives its contractual change-of-beneficiary procedures, and a person who proves that the owner of the account clearly intended to designate him or her as the beneficiary does not also need to prove that the owner substantially complied with the change-of-beneficiary procedures in order to recover. Instead, the account owner's clearly expressed intent controls. Because this holding rejected the analysis adopted by the Second District Court of Appeals in this case and because there existed a genuine issue of fact as to the intent of the account owner, the Supreme Court reversed the court of appeals' judgment and remanded to the common pleas court for trial. View "LeBlanc v. Wells Fargo Advisors, LLC" on Justia Law