Justia Ohio Supreme Court Opinion Summaries

The Supreme Court granted in part and denied in part a writ of mandamus challenging the decision of the Ohio General Assembly placing a proposed amendment to the Ohio Constitution on the ballot for a special election to be held on August 8, 2023, holding that a writ was warranted in part.In May 2023, the Ohio General Assembly passed a joint resolution to place to placed a proposed amendment to the Ohio Constitution on the ballot for a special election. Relators filed this original action against Secretary of State Frank LaRose and the Ohio Ballot Board arguing that the ballot language and title of the proposed amendment were incomplete and misleading. The Supreme Court granted the writ in part, holding that LaRose's use of the word "any" in reference to "constitutional amendment" in the ballot title was likely to mislead voters, and the ballot board shall reconvene to adopt lawful ballot language that accurately characterizes and explains the definition of "electors" in reference to the petition signature requirements in the proposed amendment. View "State ex rel. One Person One Vote v. Ohio Ballot Bd." on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that there was not an enforceable settlement agreement between Jack Marchbanks, director of the Ohio Department of Transportation (ODOT), and Ice House Ventures, LLC, Lion Management Services, LLC, and Smokestack Ventures, LLC (collectively, IHV), holding that there was an enforceable settlement agreement.IHV and ODOT entered into the settlement agreement at issue related to an appropriation proceeding resulting from ODOT's exercise of eminent domain over property owned by IHV. The trial court granted IHV's motion to enforce the agreed judgment entry on the settlement and awarded damages to IHV. The court of appeals reversed, holding that the trial court erred in enforcing the settlement because there was no meeting of the minds on a material term of the settlement. The Supreme Court reversed, holding that ODOT did not show by clear and convincing evidence that it was entitled to rescission of the agreement or that any lack of understanding about the term "damages" in the agreement rendered it unenforceable. View "Marchbanks v. Icehouse Ventures, LLC" on Justia Law

In this action arising from an initiative petition proposing a constitutional amendment entitled "The Right to Reproductive Freedom with Protections for Health and Safety" the Supreme Court held that Relators, registered Ohio voters, were not entitled to a writ of mandamus.The Ohio Ballot Board and its members determined that the initiative petition proposed a single constitutional amendment to the Ohio Constitution that would protect an individual's "right to make and carry out one's own reproductive decisions." Relators commenced this action ordering the Board to issue a determination that the petition contained more than one amendment. The Supreme Court denied the writ, holding that the ballot board did not abuse its discretion or disregard applicable law in determining that petition at issue contained a single constitutional amendment. View "State ex rel. DeBlase v. Ohio Ballot Bd." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellants' action for a writ of prohibition against Appellees - Ashtabula County Court of Common Pleas Judge Marianne Sezon and Clerk of Court April Daniels - and denied Appellants' motion for oral argument, holding that Appellants failed to state a claim upon which a writ of prohibition could be granted.In a forcible entry and detainer action Judge Sezon ordered Appellants to vacate the premises at issue. The parties subsequently reached a settlement agreement, but Appellants did not vacate the premises by the agreed-upon date. The underlying plaintiff subsequently moved for a writ of restitution. Appellants filed a complaint for a writ of prohibition, arguing that the trial court lacked jurisdiction. The court of appeals denied and dismissed the motion. The Supreme Court affirmed, holding that Judge Sezon did not patently and unambiguously lack jurisdiction over the postjudgment proceedings before her. View "State ex rel. Allenbaugh v. Sezon" on Justia Law

The Supreme Court affirmed the judgment of the Tenth District Court of Appeals denying Appellant's action seeking a writ of mandamus ordering the Ohio Parole Board to reinstate his parole and hold a new revocation hearing, holding that there was no error.Appellant was released on parole in 2019 after his incarceration for murder and other crimes. He was subsequently arrested for violating the terms of his parole. After a hearing, the Ohio Parole Board revoked Appellant's parole, finding that he had engaged in sexual contact with a woman without her consent. The Tenth District denied Appellant's subsequent petition seeking a writ of mandamus ordering the parole board to reinstate his parole and hold a new revocation hearing. The Supreme Court affirmed, holding that Appellant did not show by clear and convincing evidence that he was entitled to a writ of mandamus. View "State ex rel. Cartwright v. Ohio Adult Parole Bd." on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus to compel the common pleas court judge who sentenced him to correct what he alleged was an illegal sentence, holding that a court must give the parties notice and an opportunity to be heard before taking notice of facts contained in another court's dockets and relying on those facts to sua sponte dismiss a complaint for failure to comply with Ohio Rev. Code 2969.25.Appellant filed a complaint for a writ of mandamus arguing that his sentence for attempted murder with specifications was unlawful. The court of appeals sua sponte dismissed the complaint on the grounds that Appellant had failed to comply with section 2969.25(A). The Supreme Court reversed, holding that the court of appeals erred by consulting the record of another case in another court to determine the accuracy of Appellant's section 2969.25(A) and by dismissing Appellant's complaint based on information it obtained without first giving him notice and an opportunity to be heard. View "State ex rel. Roush v. Hickson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's complaint for a writ of habeas corpus against the warden of the Madison Correctional Institution, holding that the court of appeals correctly denied Appellant's petition for a writ of habeas corpus.Appellant was convicted of rape, felonious sexual penetration, and gross sexual imposition. Appellant later filed the complaint for a writ of habeas corpus at issue in this case, alleging that the trial court had sentenced him for an offense when it lacked jurisdiction to do so and, alternatively, that the trial court failed to impose a judgment that satisfied the requirements of Crim.R. 32. The court of appeals denied the writ. The Supreme Court affirmed and denied Appellant's motion for transcripts and journal entires, holding that Appellant's propositions of law were either waived or that Appellant's remedy did not lie in habeas corpus. View "State ex rel. Haddix v. Warden" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus seeking release from custody on bail on reasonable conditions of bond, holding that habeas corpus was not the proper action by which to challenge the trial court's denial of bail.Appellant, who was being held without bail pending trial for rape and other charges, filed a verified complaint seeking a writ of habeas corpus ordering the Franklin County Sheriff Dallas Baldwin to release him from custody and "let him to bail" upon reasonable conditions of bond. The court of appeals granted the sheriff's motion to dismiss. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law by means of appeal from the denial of his requests for pretrial release on bail, thus excluding extraordinary relief in habeas corpus. View "State ex rel. Garcia v. Baldwin" on Justia Law

The Supreme Court affirmed the judgment of the Tenth District Court of Appeals issuing a limited writ of mandamus directing the Industrial Commission of Ohio to vacate its order denying Amanda Carpenter's request for death benefits after her fiancé, Christopher McDonald, died in an industrial accident, holding that a writ of mandamus was appropriate.In denying Carpenter's request for death benefits the Commission determined that Carpenter was not McDonald's surviving spouse. In issuing its limited writ of mandamus the Tenth District concluded that Carpenter could potentially qualify for death benefits as a member of McDonald's family. The court directed the Commission to vacate its order and to determine whether Carpenter was a member of McDonald's family under Ohio Rev. Code 4123.59(D) and, if so, the extent of her dependency. The Supreme Court affirmed, holding that Carpenter had a clear legal right to have the Commission apply section 4123.59(D) correctly to her claim for death benefits, and the Commission had a clear legal duty to do so. View "State ex rel. McDonald v. Industrial Comm'n of Ohio" on Justia Law

The Supreme Court granted a writ of prohibition against the Logan County Common Pleas Court and Judge Natasha Kennedy, a judge of the Logan County Common Pleas Court, Family Court Division, holding that Relators, Josephine Davis, John Doe, and Jane Doe, were entitled to the writ.Davis, the biological mother of H.P., consented to the placement of care, custody, and control over H.P. to John and Jane Doe for purposes of adoption. The Does then filed an adoption petition for H.P. Thereafter, Kaidin Whitrock, H.P.'s biological father, filed a complaint to allocate parental rights and responsibilities. The probate court determined that Whitrock's consent to the adoption was not required under Ohio Rev. Code 3107.07(B)(1) because he failed to register as the putative father. The district court reversed, but the Supreme Court reversed. At issue was whether Judge Kennedy could continue to exercise juvenile court jurisdiction without interfering with the exclusive, original jurisdiction of the probate court. The Supreme Court granted Relators' requested writ of prohibition, holding that Judge Kennedy may not continue to exercise jurisdiction over Whitrock's petition to allocate parental rights and his request for a temporary order of parenting time. View "State ex rel. Davis v. Kennedy" on Justia Law