Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Relator's petition seeking a writ of prohibition to vacate his conviction and sentence for certain felony offenses, holding that Relator failed to show that he was entitled to the writ.In his petition, Relator sought a writ of prohibition to, among other things, prohibit and vacate the transfer of his criminal case from one judge to another. The court of appeals granted the judges' motion to dismiss the petition. The Supreme Court affirmed, holding that Relator failed to show by clear and convincing evidence that he was entitled to a writ of prohibition, as he had an adequate remedy in the ordinary course of the law, and the trial court did not patently and unambiguously lack subject-matter jurisdiction. View "State ex rel. Smith v. Triggs" on Justia Law

The Supreme Court reversed the judgment of the court of appeals in this second lawsuit brought by AJZ's Hauling, LLC against TruNorth Warranty Programs of North American (TruNorth) affirming the decision of the trial court denying TruNorth's motion to stay and compel arbitration, holding that the claims filed by AJZ's Hauling against TruNorth were subject to arbitration.AJZ's Hauling purchased a truck that came with a TruNorth warranty. AJZ's Hauling later sued TruNorth, and the trial court granted TruNorth's motion to stay the proceedings and to compel arbitration. AJZ's then filed a second lawsuit raising the same claims it had alleged against TruNorth in the first lawsuit. TruNorth again filed a motion to stay and to compel arbitration, which the trial court denied. The court of appeals affirmed, concluding that application of the doctrine of res judicata would be unreasonable or unjust. The Supreme Court reversed, holding (1) AJZ's Hauling's claims filed against TruNorth in the second lawsuit were subject to arbitration; and (2) an exception to application of the doctrine of res judicata to avoid unjust results does not apply when the parties had a full opportunity to litigate the issue and chose not to do so. View "AJZ Hauling, LLC v. TruNorth Warranty Program of N. America" on Justia Law

The Supreme Court denied as moot Mark Griffin's request for a writ of mandamus and also denied Griffin's request for statutory damages, holding that Griffin's request for a writ of mandamus was moot.Griffin, an inmate at the Toledo Correctional Institution, submitted a public-records request to Allan Szoke, a warden's assistant at the Ohio Department of Rehabilitation and Correction. Griffin later brought this action seeking a writ of mandamus compelling production of the records and an award of statutory damages. The Supreme Court denied the writ, holding (1) because Griffin had received the requested records, his request for a writ of mandamus was moot; and (2) Griffin was not entitled to statutory damages because he did not clearly and convincingly show that Szoke denied his public-records request or otherwise failed to fulfill his duties under the Public Records Act. View "State ex rel. Griffin v. Szoke" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying the writ of mandamus sought by Stephen Harris to order the Industrial Commission of Ohio to reverse its decision denying Harris's request for scheduled-loss compensation for the permanent partial loss of sight of both eyes, holding that there were no grounds for the writ.After the Commission denied Harris's request for scheduled-loss compensation a district hearing officer determined that the medical evidence failed to establish that Harris had sustained any loss of vision in either eye as a result of the industrial injury. Harris filed a mandamus action requesting an order directing the Commission to reverse its decision. The court of appeals denied the writ. The Supreme Court affirmed, holding that some evidence existed to support the Commission's decision. View "State ex rel. Harris v. Industrial Comm'n" on Justia Law

The Supreme Court denied a writ of mandamus brought under Ohio's Public Records Act, Ohio Rev. Code 149.43, by Harry Barr, an inmate at the Grafton Correctional Institution (GCII), seeking to compel the warden's assistant at GCI to produce the job description for, and the certification or license held by, Jennifer Whitten, a GCI employee, holding that Barr was not entitled to the writ.In addition to the writ of mandamus, Barr sought statutory damages and also filed a complaint for a temporary restraining order (TRO) and a preliminary injunction and other motions. The Supreme Court dismissed Barr's complaint for a TRO and a preliminary injunction, granted Barr's motion to amend the evidence and deemed the record supplemented, granted his motion to withdraw his motion for an order pursuant to S.Ct.Prac.R.4.01(A), and denied the writ of mandamus and his request for statutory damages, holding that Barr was entitled to some relief. View "State ex rel. Barr v. Wesson" on Justia Law

The Supreme Court granted Harry Barr a limited writ of mandamus, holding that Barr was entitled to relief on his request for certain inmate records predating State ex rel. Mobley v. Ohio Dep't of Rehabilitation & Correction, 201 N.E.3d 853 (Ohio 2022).Barr, an inmate, sought certain documents from James Wesson, the institutional public information officer at Grafton Correctional Institution (GCI), pursuant to Ohio's Public Records Act, Ohio Rev. Code 149.43. Wesson produced some records and, as to the remaining, claimed that Barr failed sufficiently to specify which records he wanted and that Barr's requests predated Mobley, thus rendering them unenforceable. The Supreme Court granted Barr a limited writ of mandamus as to prison-kite logs predating Mobley, ordered Wesson to produce the email messages that Barr requested if they exist, denied the writ as to Barr's request for a list of cross-gender employees, dismissed his complaint for a temporary restraining order and preliminary injunction, and denied his motion to strike a certain affidavit, holding that Barr demonstrated that he had a clear legal right to access the prison-kite logs and specified email messages if they existed. View "State ex rel. Barr v. Wesson" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals in this case involving Ohio's sex-offender registration and reporting laws, holding that Appellant had completed his Ohio sex-offender registration and reporting obligations.Specifically, the Court held (1) the holding in State v. Henderson, 162 N.E.3d 776 (Ohio 2020), that when a court has jurisdiction to act, any errors in the court's judgment are voidable and subject to res judicata if they are not timely appealed, does not apply to a trial court's erroneous classification of a defendant as a Tier I sex offender subject to the registration and reporting requirements of Ohio's Adam Walsh Act (AWA), 2007 Am.Sub.S.B. No. 10, when the date on which the defendant committed the offense rendered the defendant subject to the registration and reporting requirements of Ohio's Megan's Law, Am.Sub.H.B. No. 180, and Ohio's sex-offender registration and reporting scheme that predated the AWA, Am.Sub.S.B. No. 5; and (2) a person's obligation to register and report as a sex offender in Ohio for a specific duration is not tolled when the person was convicted of a sexually-oriented offense in Ohio but resides in a different state and reports as a sex offender regarding the out-of-state offense. View "State v. Schilling" on Justia Law

The Supreme Court declined to issue a writ of prohibition sought by Youngstown Civil Service Commission, the City of Youngstown and Youngstown Mayor Jamael Tito Brown (collectively, Youngstown) to prevent Mahoning County Court of Common Pleas Judge Maureen Sweeney from exercising jurisdiction over an administrative appeal commenced by Michael Cox and to require her to vacate all orders issued in the appeal, holding that Youngstown was not entitled to the writ.Youngstown commenced this action seeking a writ of prohibition prohibiting Judge Sweeney from exercising any judicial authority over the underlying action and vacating all orders and journal entires issued in that case. As grounds for the writ, Youngstown argued that Judge Sweeney patently and unambiguously lacked jurisdiction over it because the pending underlying action was an untimely administrative appeal. The Supreme Court denied the writ, holding that Judge Sweeney did not patently and unambiguously lack jurisdiction over the matter at issue. View "State ex rel. Youngstown Civil Service Commission v. Sweeney" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's partial denial of Defendant's motion for summary judgment in this dog bite case, holding that a genuine issue of material fact existed, precluding summary judgment.Defendant in this case was a deputy sheriff and K-9 handler who hosted a cookout for friends at his home. Plaintiff, who attended the cookout, was bitten by Defendant's canine partner, Xyrem. Plaintiff brought suit, asserting a common-law negligence claim and a claim under Ohio Rev. Code 955.28, which imposes strict liability for injuries caused by a dog in certain situations. The trial court granted Defendant's motion for summary judgment in part, determining that Defendant was immune from liability under section 955.28(B). Defendant appealed the denial of summary judgment on the negligence claim. The court of appeals reversed, holding that, as a matter of law, Defendant was not manifestly acting outside the scope of his employment or official responsibilities during the evening of the dog bite. The Supreme Court reversed, holding that reasonable minds could differ regarding whether Defendant was manifestly acting outside the scope of his employment during the events leading up to Plaintiff's injury. View "Harris v. Hilderbrand" on Justia Law

In this employment action, the Supreme Court held that under the plain language of Ohio Rev. Code 124.48, a "vacancy" occurs for competitive promotional examination purposes when the incumbent in the promoted-rank position in the fire department retires and therefore the position must be filled through the process set forth in section 124.48.Specifically at issue was whether a position is rendered vacant for purposes of section 148.48 when the incumbent in that position retires but is rehired for the same position the next day. The court of appeals concluded that the retirement in question did not create a vacancy. The Supreme Court reversed, holding that whether an incumbent intends to permanently leave a position or to leave with the expectation of immediately returning to that position is irrelevant to the determination of whether the incumbent's leaving creates a vacancy under the terms of section 149.48. View "State ex rel. Int'l Ass'n of Fire Fighters, Local 1536, AFL-CIO v. Sakacs" on Justia Law