Justia Ohio Supreme Court Opinion Summaries

The Supreme Court granted a writ of mandamus sought by Harm Reduction Ohio (HRO) ordering OneOhio Recovery Foundation (the Foundation) to provide requested documents under Ohio's Public Records Act, Ohio Rev. Code 149.43 and denied HRO's requests for statutory damages and attorney fees, holding that the Foundation was bound by the Public Records Act.HRO, a statewide nonprofit organization with a mission to prevent overdose deaths, sent a public records request to the Foundation seeking documents prepared for the OneOhio Recovery Foundation Board for certain meetings. Alleging that the Foundation did not respond, HRO filed this action seeking a writ of mandamus directing the Foundation to allow access to the requested records. The Supreme Court granted a writ of mandamus ordering the Foundation to provide the public record responsive to HRO's public records request, holding that HRO demonstrated by clear and convincing evidence that it had a clear legal right of access to the requested records. View "State ex rel. Harm Reduction Ohio v. OneOhio Recovery Foundation" on Justia Law

The Supreme Court denied Relator's complaint seeking a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction (DRC) to provide documents in response to submitted public records requests, holding that this action was moot.Relator, an inmate at the London Correctional Institution, sent several requests to the DRC for records and kites. DRC provided a requested record and concluded that the remaining records were electronic kites. Relator then made subsequent requests. The DRC denied the requests and ultimately gave Relator a formal directive to stop the repetitive requests. Relator then filed his mandamus complaint. The Supreme Court denied the writ and awarded Relator $1,000 in statutory damages, holding (1) Relator's requests for the kites were moot because the DRC provided all the requested kites; and (2) Relator was entitled to statutory damages. View "State ex rel. Straughter v. Ohio Dep't of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against the warden of the Trumbell Correctional Institution, where Appellant was serving a forty-year prison sentence, holding that there was no error.Appellant was serving his prison sentence for nine convictions for felonious assault, in violation of Ohio Rev. Code 2903.11(B)(3). Appellant filed a petition for a writ of habeas corpus arguing, inter alia, that section 2903.11(B)(3) violates the Equal Protection Clauses of the Ohio and United States Constitution. The court of appeals dismissed the petition for failure to state a valid claim for habeas relief. The Supreme Court affirmed, holding that habeas corpus did not lie for Appellant's nonjurisdictional claims. View "Christian v. Davis" on Justia Law

The Supreme Court remanded this case to the trial court for it to enter a judgment of conviction against Appellant for criminal trespass under Ohio Rev. Code 2911.21(A)(1) and to sentence him in accordance with this opinion, holding that insufficient evidence supported Appellant's conviction of burglary.Under Ohio Rev. Code 2911.12(A)(2), the State was required to prove that Appellant trespassed by "force, stealth, or deception" in order to convict him of burglary. The court of appeals affirmed the conviction. The Supreme Court reversed and vacated Appellant's burglary conviction and judicial sanction, holding (1) to prove a defendant trespassed by stealth or deception in a burglary case the State must prove that the defendant actively avoided discovery or used deceptive conduct to gain entry to the structure; and (2) the evidence in this case was insufficient to convict Appellant of burglary but sufficient to convict him of criminal trespass. View "State v. Bertram" on Justia Law

The Supreme Court refused to grant a writ of mandamus directing the Delaware County Sheriff's Office (DCSO) to produce records in response to a public-records request, holding that Relator failed to prove that he was entitled to relief by clear and convincing evidence.Relator, an inmate, sent a public-records request to DCSO seeking a variety of records. Twelve days later, Relator sent a second request to DCSO seeking twelve categories of records. DCSO responded to the first request with a letter and DVD containing responsive records. Relator then commenced this action seeking a writ of mandamus ordering DCSO to provide the records identified in his second request. The Supreme Court denied the mandamus claim, holding that Relator failed to demonstrate that he was entitled to mandamus relief and that DCSO had a clear legal duty to provide that relief. The Court further denied Relator's requests for statutory damages, court costs, and attorney fees. View "State ex rel. Howson v. Delaware County Sheriff's Office" on Justia Law

The Supreme Court granted in part and denied a writ of mandamus sought by Relator compelling the clerk of the Circleville Municipal Court, Charma Cantrell, to comply fully with a public-records request Relator sent Cantrell under the Public Records Act, Ohio Rev. Code 149.43(B), holding that Relator was entitled to the writ in part.Relator, an inmate, brought this action demanding a writ of mandamus ordering Cantrell either to produce all records responsive to his January 2022 records request or explain why such records would not be produced. The Supreme Court granted the writ in part, holding (1) Relator was entitled to a writ of mandamus on his request to strike the evidence attached to Cantrell's merit brief because it was untimely submitted; and (2) Relator was not entitled to relief on his remaining arguments. View "State ex rel. Adkins v. Cantrell" on Justia Law

The Supreme Court granted in part and denied in part the Lawrence County Sheriff's Office's motion for judgment on the pleadings as to this action brought by Relator, an inmate, and denied as moot Relator's claim for a writ of mandamus, holding that the mandamus claim was moot.Relator sought certain records from the Lawrence County Sheriff's Office, which determined that the request was too vague to grant. Relator then filed this action requesting, among other things, a writ of mandamus ordering the Sheriff to produce the requested records and seeking awards of statutory damages, attorney fees, and court costs. The Sheriff filed a motion for judgment on the pleadings. Thereafter, Relator received the requested records. The Supreme Court held (1) the Sheriff was entitled to judgment on the pleadings as to Relator's mandamus claim, which was moot; (2) Relator was entitled to $700 in statutory damages but was not entitled to attorney fees and court costs; and (3) Relator's remaining motions were moot. View "State ex rel. Woods v. Lawrence County Sheriff's Office" on Justia Law

The Supreme Court dismissed this appeal of the decision of the court of appeals setting Appellant's bail at $250,000, holding that this appeal was moot.Appellant was indicted on several charges and arrested, and the trial court set bail at $500,000. The court of appeals granted Appellant's petition for a writ of habeas corpus on the grounds that his bail was unconstitutionally excessive and reduced his bail to $250,000. After Appellant appealed, he pleaded guilty and was sentenced. The Supreme Court dismissed the appeal from the bail order, holding that Appellant's appeal was moot, and Appellant had not shown that a mootness exception applied in this case. View "State ex rel. Casanova v. Lutz" on Justia Law

The Supreme Court denied Relator's petition in this original action seeking a writ of mandamus to compel the city of Sheffield Lake and its mayor (collectively, the city) to produce documents in response to a public records request sent by Relator, holding that Relator failed to establish that he was entitled to the requested relief.Relator, a city police officer and the city's only black officer at the time, submitted a public records request for records relating to an incident in which Anthony Campo, the city's former police chief, resigned after placing a "KKK" sign across the back of Relator's coat to cover the word "POLICE," donned a paper KKK hat and told Relator he should wear one on his next police call. The city provided only partial responses to the request. Relator then brought this mandamus action. The Supreme Court denied relief, holding (1) the evidence showed that the city made reasonable efforts to locate the documents; and (2) Relator's requests for awards of statutory damages, attorney fees, and court costs are also denied. View "State ex rel. Pool v. Sheffield Lake" on Justia Law

The Supreme Court granted a writ compelling the Mansfield Correctional Institution to produce records requested by Relator against the Mansfield Correctional Institution under Ohio's Public Records Act, Ohio Rev. Code 149.43, holding that Relator was entitled to a writ.Relator requested information and records from the prison warden's office regarding three assaults committed against her son while he was incarcerated at the prison. After the prison asserted that all responsive records had been produced Relator brought this action. The Supreme Court granted the writ with respect to some of the requested records and granted a limited writ compelling the prison to produce additional requested records or to certify that no responsive records existed and denied Relator's motions to transfer this case to the court of claims, to strike the prison's merit brief, and other motions, holding (1) the prison failed to prove that certain withheld information fell squarely within an exception to the Act; (2) the prison did not carry its burden of proving that no other documents existed that were responsive to certain requests; and (3) Relator was not entitled to a writ of mandamus as to the remaining evidence. View "State ex rel. Sultaana v. Mansfield Correctional Institution" on Justia Law