Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the opinion of the court of appeals affirming the decision of the trial court to grant summary judgment in favor of Defendants in this complaint alleging misappropriation of trade secrets, tortious interference with business contacts, tortious interference with business relationships, and conversion, holding that there was no error.Plaintiff, Hanneman Family Funeral Home and Crematorium, purchased a funeral home but did not retain the funeral home's director, Patrick Orians. Orians accepted employment at another funeral home, Chiles-Laman Funeral & Cremation Services, and used Plaintiff's customer information to solicit business for Chiles-Laman. Plaintiff sued Orians and Chiles-Laman (collectively, Defendants). The trial court entered summary judgment in favor of Defendants, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the information at issue was not protected by the Ohio Uniform Trade Secrets Act as a trade secret; and (2) Plaintiff's tort claims were preempted by the Ohio Uniform Trade Secrets Act. View "Hanneman Family Funeral Home & Crematorium v. Orians" on Justia Law

The Supreme Court dismissed Appellant's appeal challenging the decision of the court of appeals denying his motion for leave to continue a mandamus action, holding that Appellant's appeal was prohibited under Ohio Rev. Code 2323.52(G).Appellant filed a complaint for a writ of mandamus alleging that he made a public-records request to Appellee, Franklin County Prosecutor G. Gary Tyack, under Ohio's Public Records Act, Ohio Rev. Code 149.43, for certain documents, and that Tyack had failed to answer his request. Thereafter, in a separate case, Mobley was declared a vexatious litigator. Mobley filed a motion for leave to continue his mandamus action as a vexatious litigator, but the court of appeals denied the motion and dismissed the mandamus action. The Supreme Court dismissed Appellant's appeal, holding that the Court lacked jurisdiction to consider the appeal. View "State ex rel. Mobley v. Tyack" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus arguing that the trial court in which he was convicted lacked subject-matter jurisdiction, holding that the court of appeals correctly dismissed the petition for Appellant's failure to comply with Ohio Rev. Code 2969.25(C).Appellant was convicted on two counts of aggravated murder and sentenced to two concurrent life sentences. Appellant later filed a petition for writ of habeas corpus alleging that the trial court lacked subject matter jurisdiction and failed properly to journalize his sentencing entry. The court of appeals dismissed the petition for Appellant's failure to comply with section 2969.25(C). The Supreme Court affirmed, holding that the petition was properly dismissed due to Appellant's failure to submit a certified statement of his inmate account, as required by section 2969.25(C)(1). View "Grinnell v. Cool" on Justia Law

The Supreme Court granted a limited writ of mandamus ordering Respondent James Wesson, the warden's assistant at the Grafton Correctional Institution (CGI), to, within fourteen days, either produce records in response to a December 2022 public-records request or show cause why the records could not be produced, holding that Relator was entitled to the writ.Relator, an inmate at CGI, sent a public-records request by electronic kite to Wesson requesting three records. Relator subsequently commenced this mandamus action asking the Court to order Wesson to provide the requested records. The Supreme Court granted a limited writ ordering Wesson to produce a copy of a mental-health kite with reference number GCI0422002492 from April 21, 2022 or to show cause why it could not be produced, holding that Relator established that he was entitled to the writ. View "State ex rel. Barr v. Wesson" on Justia Law

In this case concerning how an Ohio prisoner is to enforce his constitutional right to a speedy trial on an untried indictment the Supreme Court held that a prisoner satisfies the "causes to be delivered" requirement of Ohio Rev. Code 2941.401 when he delivers the written notice and the request to the warden where he is imprisoned, even if the warden fails to deliver the notice and the request to the prosecuting attorney or the appropriate court.Appellant, who was indicted on counts of aggravated robbery and robbery, moved to dismiss the indictment on speedy-trial grounds. The trial court granted the motion, concluding that Appellant had strictly complied with section 2941.401 when he provided written notice of his place of imprisonment and a request for a final disposition and that the 180-day speedy trial time was not tolled by the warden's failure to comply with his duty to send out Appellant's written notices and requests to the prosecuting attorney or the appropriate court. The court of appeals reversed, concluding that Appellant had not strictly complied with the requirements of the statute. The Supreme Court reversed, holding that Appellant caused to be delivered his written notice and request for final disposition under the statute when he provided them to the warden. View "State v. Williams" on Justia Law

The Supreme Court denied a writ of prohibition sought by Relator ordering Cuyahoga County Board of Elections and its individual members to remove a proposed East Cleveland city-charter amendment from the November 7, 2023 general election ballot and refrain from going forward with a special mayoral-recall election, holding that Relator was not entitled to the writ.Relator, the mayor of East Cleveland, sought a writ of prohibition ordering Respondents - the Cuyahoga County Board of Elections and its individual members - to remove a proposed city-charter amendment from the November 2023 general election ballot and refrain from proceeding with a May 5, 2023 mayoral-recall election. Relator further sought a temporary restraining order and preliminary injunction asking that the elections and the mayoral recall not go forward. The Supreme Court denied the writ and denied as moot Relator's motion for a temporary restraining order and preliminary injunction, holding that Relator was not entitled to the writ of prohibition. View "State ex rel. King v. Cuyahoga County Bd. of Elections" on Justia Law

In this expedited election case, the Supreme Court granted a writ of mandamus compelling Respondents to sustain a protest compelling Secretary of State Frank LaRose and the Logan County Board of Elections to sustain a protest and remove an initiative from the November 2023 general election ballot, holding that LaRose and the board abused its discretion and disregarded the law in overruling Relators' protest.Petitioners collected signatures for an initiative petition concerning a proposed ordinance regarding drag artists and drag shows. The part-petitions that were filed, however, differed from the circulated part-petitions. The board found that the petition contained a sufficient number of valid signatures. Relators filed a protest, but Secretary LaRose voted against the protest. Relators then filed this mandamus action seeking to compel Respondents to sustain their protest. The Supreme Court sustained the writ, holding that the petition as filed did not comply with Ohio Rev. Code 731.31 because each filed part-petition included a title that was not presented to the electors who signed it. View "State ex rel. Hildreth v. LaRose" on Justia Law

The Supreme Court granted a writ of mandamus ordering the Union County Board of Elections to place a referendum on the November 7, 2023 general election ballot in this expedited election case, holding that the Union County Board of Elections and Secretary of State based their discretion and acted in clear disregard of the applicable law when they removed the referendum from the ballot.On the same day that the Marysville City Council passed an ordinance to annex 263.25 acres adjoining Marysville it passed an ordinance to rezone the territory from agricultural use to a planned-unit development. Relators circulated referendum petitions for the annexation ordinance, and the board certified the referendum to the ballot. Respondent filed an election protest to the referendum. The Secretary of State sustained the protest and excluded the referendum from the ballot. Relators then brought this action for a writ of mandamus to compel the board to place the referendum on the November 2023 general election ballot. The Supreme Court granted the writ, holding that it was an abuse of discretion to remove the referendum from the ballot. View "State ex rel. Miller v. Union County Bd. of Elections" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals issuing a limited writ of mandamus and ordering the Industrial Commission of Ohio to determine Appellee's appropriate pre-injury visual baseline and to apply that baseline to his request for compensation, holding that the Commission has discretion to use a claimant's vision as corrected by a hard contact lens as the claimant's pre-injury visual baseline.Appellee sustained an industrial injury to his right eye and underwent three surgical procedures to address the conditions allowed under his workers' compensation claim. Appellee then sought scheduled-loss compensation under Ohio Rev. Code 4123.57. After staff hearing officer denied Appellee's request Appellee filed a mandamus action arguing that the Commission had abused its discretion. The court of appeals reversed. The Supreme Court affirmed, holding that the writ was appropriate to determine Appellee's pre-injury visual baseline and to then use that baseline to determine whether the medical evidence supports an award for total loss of sight under Ohio Rev. Code 4123.57(B). View "State ex rel. Cogan v. Industrial Comm'n of Ohio" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's convictions for felony charges stemming from an inventory search of an impounded truck that Defendant was driving when he was pulled over by a law enforcement officer, holding that the search was reasonable and lawful under the Fourth Amendment.Law enforcement performed an inventory search as to the truck at issue and found a handgun in the truck's right door panel. After Defendant unsuccessfully moved to suppress the evidence of the gun the trial court found him guilty. The court of appeals reversed, holding that the search was not reasonable under the Fourth Amendment because the state's evidence was insufficient. The Supreme Court reversed, holding that the inventory search was lawful. View "State v. Toran" on Justia Law