Justia Ohio Supreme Court Opinion Summaries

Edward Lang was convicted of the aggravated murder of two persons and aggravated robbery, with each count carrying gun specifications. Lang was sentenced to death for one murder and life with no possibility of parole for the other murder. The trial court also imposed a ten-year term of imprisonment for the aggravated-robbery conviction and a three-year term for the gun specifications, which it had merged for sentencing. The Supreme Court (1) affirmed Lang's convictions and sentences of death and life without parole despite Lang's mental illness and history of abuse, but (2) remanded for the proper imposition of postrelease control pursuant to Ohio Rev. Code 2929.91 on Lang's sentence for aggravated robbery. View "State v. Lang" on Justia Law

Michael Pruitt filed writs of mandamus and prohibition to compel Appellees, common pleas court judges, to vacate his convictions and sentence. Pruitt argued that the common pleas court erred in entering a sentence that incorrectly stated that Pruitt had entered pleas of guilty to having a weapon while under disability and to a firearm specification relating to an attempted-murder charge. The court of appeals dismissed Pruitt's claims, noting that all of the cases cited by Pruitt were resolved in the ordinary course of law by appeal rather than in an action for an extraordinary writ. The Supreme Court affirmed, holding that the court of appeals properly dismissed Pruitt's claims as Pruitt had adequate remedies in the ordinary course of law to raise his claims. View "State ex rel. Pruitt v. Common Court of Pleas" on Justia Law

The Liberty Township board of trustees approved a zoning amendment that rezoned three parcels of township land. Subsequently, a group of petitioners filed a referendum petition seeking to submit the board's action approving the rezoning of the property to the electors of the township. Relators, the owner of the property at issue, the developer of the property, and the developer company's president, submitted a protest to the county board of elections against the referendum petition. The board certified the referendum petition and placed the rezoning issue on the general-election ballot and rejected Relators' protest grounds. Relators then filed this action for a writ of prohibition and a writ of mandamus to compel the board to sustain their protest. The Supreme Court granted the writ of prohibition, holding that the board of elections abused its discretion by denying Relators' protest, certifying the referendum petition, and submitting the zoning amendment to the electorate because the petitioners did not timely file their referendum petition pursuant to statute. View "State ex rel. Edwards Land Co., Ltd. v. Delaware County Bd. of Elections" on Justia Law

Virginia King was injured in an automobile accident and was treated for her injuries at Toledo Hospital. Although King informed the hospital staff that she was covered by a health-insuring corporation, the hospital billed King's automobile insurer for the services rendered. King sued the hospital and ProMedica Health System (Appellants). Each of King's causes of action was based on the claim that Appellants violated Ohio Rev. Code. 1751.60(A) by billing the automobile insurer instead of the health-insuring corporation. Section 1751.60(A) stated that every provider that contracts with a health-insuring corporation to provide health-care services to an insured shall seek payment solely from the corporation. The trial court granted Appellants' motion to dismiss, and the court of appeals reversed. At issue on appeal was whether section 1751.60(A) prohibited a provider from seeking payment for medical treatment rendered to an insured injured in an automobile accident from the insured's automobile insurance medical benefits. The Supreme Court reversed the court of appeals, holding (1) section 1751.60(A) applies only when a health-care provider seeks payment from an insured, and (2) section 1751.60(A) does not conflict with Ohio's law on the coordination of insurance benefits. View "King v. ProMedica Health Sys., Inc." on Justia Law

Five companies entered into special contracts with the Toledo Edison Company for the sale of electricity. The Public Utilities Commission of Ohio (PUCO) established February 2008 as the termination date for the contracts, basing its finding on the language of the special contracts and its orders in earlier electric-deregulation cases. Appellants challenged the decision, contending (1) Toledo Edison agreed in 2001 that the contracts would not terminate until Toledo Edison stopped collecting regulatory-transition charges from its customers, and (2) December 31, 2008 was the date when Toledo Edison stopped collecting regulatory-transition charges. The Supreme Court reversed, holding that the PUCO ignored the plain language of the 2001 amendments to Appellants' special contracts, and accordingly, the PUCO unlawfully and unreasonably allowed Toledo Edison to terminate the special contracts in February 2008. View "Martin Marietta Magnesia Specialties, L.L.C. v. Pub. Util. Comm'n " on Justia Law

Christopher Barker pleaded guilty to five counts of unlawful sexual conduct with a minor. On appeal, Barker argued that the entry of his no-contest plea was not voluntary, intelligent, and knowing because the trial judge had failed to fully comply with the requirements of Ohio R. Crim. P. 11(C) when the judge told Barker that by entering the plea he was giving up the "right to call witnesses to speak on his behalf." The court of appeals agreed and reversed the judgment of the trial court, holding that the trial court's admonition to Barker was insufficient to satisfy the constitutional mandate to compulsory process. The Supreme Court reversed the judgment of the court of appeals, holding (1) the language employed by the trial court while addressing Barker was a reasonable explanation of Barker's right to compulsory process, and (2) other portions of the record may be referenced in resolving an alleged ambiguity such as the one here during the oral colloquy. View "State v. Barker" on Justia Law

The Industrial Commission of Ohio found that Angela Benedetti, Inc. (ABI) violated two newly added specific safety requirements that resulted in an injury to an ABI employee. ABI filed a complaint in mandamus in the court of appeals, alleging that the commission abused its discretion in permitting the injured employee to amend his specific safety requirement violations application and in finding violations of the specific safety requirements. The court of appeals upheld the Commission's order and denied the writ. On appeal, the Supreme Court affirmed, agreeing with the reasoning provided by the court of appeals but not given in this opinion. View "State ex rel. Angelo Benedetti, Inc. v. Indus. Comm." on Justia Law

American Electric Power operating companies (AEP) had been providing service to a pair of manufacturing customers at discounted rates. AEP had been keeping track of its delta revenue, the difference between what AEP would have collected under its tariffs and what it actually collected with the discount, and intended to collect it through a rider. In the case below, AEP filed an application seeking permission to collect its delta revenue through the rider. Industrial Energy Users-Ohio (IEU) opposed both requests. The Public Utilities Commission rejected IEU's arguments and allowed the American Electric Power operating companies (AEP) to recover the costs arising from the discounted-rate arrangements. IEU appealed. The Supreme Court affirmed, holding (1) IEU did not show that the Commission erred in modifying the phase-in of AEP's rates, and (2) IEU did not show that the Commission erred in calculating AEP's carrying charges. View "In re Application of Columbus S. Power Co." on Justia Law

After a jury trial, Thomas Dunlap was convicted of two counts of gross sexual imposition involving victims under the age of thirteen, in violation of Ohio Rev. Code 2907.05(A)(4), and one count of disseminating obscene matter to juveniles. The court sentenced Dunlap to two years in prison and found Dunlap to be a tier three sex offender under Ohio Rev. Code 2950, Am.Sub.S.B. No. 10 (S.B. 10). Dunlap appealed the section 2907.05(A)(4) convictions and his sex-offender classification, arguing that (1) section 2907.05(A)(4) requires a men rea element of recklessness, and (2) the application of S.B. 10 to offenses committed before its effective date violated the retroactivity clause of the Ohio Constitution. The court of appeals affirmed, holding, inter alia, that section 2907.05(A)(4) requires no precise culpable state of mind. The Supreme Court affirmed in part and reversed in part, holding (1) the element of sexual contact in a section 2907.05(A)(4) violation requires a mens rea of purpose, but the indictment and jury instructions in this case sufficiently set forth the required mens rea; and (2) the application of S.B. 10 to Dunlap violated the retroactivity clause of the Ohio Constitution. Remanded. View "State v. Dunlap" on Justia Law

Insured submitted a claim to Insurer after his house was damaged by a storm. Insured returned the payment tendered to him by Insurer, deeming the amount insufficient to cover the damage to his home. Almost two years after the house was damaged, Insured filed suit against Insurer. Insurer argued the lawsuit was barred by a clause in the insurance contract that stated that any action must be started within one year after the date of loss or damage. The trial court granted Insurer's motion for summary judgment. The court of appeals reversed, concluding the policy language was ambiguous and that Insurer, by its actions, had waived its right to enforce the one-year limitation clause. The Supreme Court reversed the judgment of the court of appeals and reinstated the trial court's grant of summary judgment, holding that Insurer could enforce the limitation-of-action clause contained in its contract because (1) the policy language was not ambiguous, and (2) Insurer did not waive its right to enforce the clause. View "Dominish v. Nationwide Ins. Co." on Justia Law