Justia Ohio Supreme Court Opinion Summaries

This case was a public-records action in which relator, ESPN, Inc., sought certain records from respondent, Ohio State University. Ohio State rejected ESPN's requests because the university deemed them to be "overly broad per Ohio's public record laws." EPSN then filed this action for a writ of mandamus to compel Ohio State to provide access to the requested records. The Supreme Court (1) granted the writ for limited records that should have been disclosed because they were not exempt from disclosure based on the Family Educational Rights and Privacy Act (FERPA); but (2) denied the writ for the rest of the records because Ohio State established that FERPA and the attorney-client privilege prohibited the disclosure of the requested records. View "State ex rel. ESPN, Inc. v. Ohio State Univ." on Justia Law

After a jury trial, Appellant Maxwell White was convicted of aggravated murder with capital specifications and sentenced to death. The Supreme Court affirmed. White subsequently obtained federal habeas corpus relief from his death sentence, obliging the trial court to resentence him. Before the federal court invalidated White's death sentence but after White killed the trooper, the Legislature enacted Ohio Rev. Code 2929.06(B), which requires the trial court, when resentencing a capital offender whose death sentence has been set aside, to empanel a new jury and conduct a fresh penalty hearing, at which death may be a penalty to be considered by the jury. The trial court held it could not retroactively apply the statute in resentencing White, and therefore, White was ineligible for a death sentence. The court of appeals reversed. The Supreme Court affirmed, holding (1) the Retroactivity Clause of the Ohio Constitution does not bar the statute's retroactive application in cases where the aggravated murder was committed before its enactment but the death sentence was set aside after its enactment; (2) the statute's application in this case does not violate the ex post facto clause; and (3) retroactive application of the statute does not violate the Double Jeopardy Clause. View "State v. White" on Justia Law

Appellant had an allowed workers' compensation claim arising from a 2002 injury. Appellant retired from Appellee a year later and never worked again. In 2009, the Industrial Commission of Ohio denied Appellant's application for temporary total disability compensation (TTC) after finding, among other things, that Appellant had abandoned the work force for reasons unrelated to his injury. Appellant subsequently filed a complaint in mandamus in the court of appeals, alleging that the Commission had abused its discretion in denying TTC. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant could not credibly assert that he had lost income due to his industrial injury, and therefore, the Commission did not err in denying TTC. View "State ex rel. Corman v. Allied Holdings, Inc." on Justia Law

Appellants were defendants in a tort action instituted by Appellees, executors of a decedent's estate. Appellees' complaint alleged, inter alia, negligence, violation of the Ohio Nursing Home Patients' Bill of Rights, and wrongful death. Appellants filed motions to bifurcate the trial to separate Appellees' claims for compensatory damages from their claims for punitive damages. The common pleas court denied the motions. The court of appeals dismissed Appellants' appeal for lack of a final, appealable order. The Supreme Court reversed, holding that the court of appeals erred in dismissing the appeal, as the trial court's order denying Appellants' motions to bifurcate the trial constituted a final, appealable order pursuant to Ohio Rev. Code 2505.02(B)(6). Remanded for application of Havel v. Villa St. Joseph. View "Flynn v. Fairview Vill. Ret. Cmty., Ltd." on Justia Law

A jury convicted Wayne Powell of the aggravated murder of four victims and of aggravated arson. The jury recommended the sentence of death for the aggravated murder of the victims. The trial court accepted those recommendations and sentenced Powell accordingly. The Supreme Court affirmed Powell's convictions and sentences of death, finding no reversible error regarding (1) any pretrial and trial issues; (2) any penalty-phase issues; or (3) counsel's effectiveness during both phases of the trial. In addition, the court held that because Powell received a fair trial, the doctrine of cumulative error was not applicable to the present case, and Powell's death sentence was appropriate and proportionate. View "State v. Powell" on Justia Law

In this action the Cincinnati City School District Board of Education asked the Supreme Court to rule on the validity of a deed restriction it placed on school property that it offered for sale at a public auction. At issue was whether the deed restriction contravened public policy by preventing an unused school building from being used by a public charter school. The trial court concluded that the deed restriction was void as against public policy, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) because this case involved a contract between a private party and a political subdivision, there was a compelling reason to apply the principle of the public policy exception to parties' rights to make contracts; and (2) therefore, the inclusion of a deed restriction preventing the use of property for school purposes in the contract for sale of an unused school building was unenforceable as against public policy. View "Cincinnati City Sch. Dist. Bd. of Educ. v. Conners" on Justia Law

Appellants, Donald and Tamara Troyer, filed a medical-malpractice complaint against Appellee, Leonard Janis. In response, Appellee filed a motion for summary judgment in which he alleged that the claims asserted against him in the complaint had already been filed and dismissed in a previous action and were now barred by the doctrine of res judicata. In support of his motion, Janis attached a copy of the complaint in the prior case, the trial court's decision granting his motion to dismiss for failure to file an affidavit of merit, and the court's judgment of entry. The trial court granted summary judgment for Janis, and the court of appeals affirmed. The Supreme Court reversed, holding that a dismissal of a complaint for failure to attach the affidavit of merit is an adjudication otherwise than on the merits and is a dismissal without prejudice by operation of law. Remanded. View "Troyer v. Janis" on Justia Law

Defendant Carl Morris was convicted by a jury of two counts of rape involving a minor. Defendant appealed, contending that the trial court abused its discretion when it admitted evidence of other acts to prove the character of a person in order to show that the person acted in conformity therewith, in violation of Ohio R. Evid. 404(B). A divided appellate court vacated the conviction, concluding that the trial court improperly admitted other-acts testimony, that the court's error was not harmless, and that the error materially prejudiced Defendant. The Supreme Court reversed, holding (1) an appellate court is to apply an abuse-of-discretion standard of review when considering an assignment of error that claims the trial court improperly admitted evidence of other acts to prove the character of a person in order to show action in conformity therewith, in violation of Rule 404(B); and (2) the appellate court erred when it applied a de novo standard of review to this matter. Remanded. View "State v. Morris" on Justia Law

At issue in this case was whether Hamilton Township, a limited-home-rule township, was authorized under Ohio law to impose its system of impact fees upon applicants for zoning certificates for new construction or redevelopment within its unincorporated areas. Appellants, several development companies, brought this action against Appellees, the Township and its trustees, seeking a declaratory judgment, injunctive relief, and damages, alleging that the impact fees were contrary to Ohio law and were unconstitutional. The trial court granted summary judgment for the Township, and the court of appeals affirmed. The Supreme Court reversed, holding (1) the impact fees charged by the Township in this case constituted taxes; and (2) since those taxes were not authorized by general law, the Township was unauthorized to impose them pursuant to Ohio Rev. Code 504.04(A)(1). View "Drees Co. v. Hamilton Twp." on Justia Law

At issue in this appeal was whether a court should enforce several employees' noncompete agreement transfers by operation of law to the surviving company when the company that was the original party to the agreement merged with another company. Here the trial court concluded that the employees did not intend to make the noncompete agreements assignable to successors such as the surviving company. The court of appeals affirmed. The Supreme Court affirmed, holding that in this case, the language the agreement dictated that the surviving company could not enforce the agreement after the merger as if it had stepped into the shoes of the original company. View "Acordia of Ohio, LLC v. Fishel" on Justia Law