Justia Ohio Supreme Court Opinion Summaries

The Supreme Court granted a limited writ of mandamus ordering Secretary of State Frank LaRose to reconvene the Ohio Ballot Board and directed the ballot board to adopt ballot language that accurately described a proposed amendment regulating actions of the "State," holding that the term "citizens of the State" in the ballot language was misleading.At issue was a constitutional amendment proposed by initiative petition titled "The Right to Reproductive Freedom with protections for Health and Safety" and the ballot language adopted by the ballot board for the November 7, 2023 election. Relators sought a writ of mandamus. The Supreme Court granted a limited writ ordering the ballot board and LaRose to reconvene and adopt ballot language that accurately conveyed that the proposed amendment limited the ability of the state, as defined by the amendment, to burden, penalize, or prohibit abortion. View "State ex rel. Ohioans for Reproductive Rights v. Ohio Ballot Bd." on Justia Law

The Supreme Court denied a writ of mandamus sought under Ohio's Public Records Act, Ohio Rev. Code 149.43, by Ashley Fluty against the City of Broadview Heights as well as Fluty's requests for statutory damages, attorney fees, and court costs, holding that Fluty was not entitled to any of the requested relief.Fluty brought this action seeking to compel Broadview Heights to produce records related to an incident of suspected child abuse and also requested awards of statutory damages, attorney fees, and court costs. The Supreme Court denied all requested relief, holding (1) Fluty failed to show that she had a clear legal right to the requested writ of mandamus and that Broadview Heights had a clear legal duty to provide it; (2) Fluty's arguments supporting her claim for an award of statutory damages were unavailing; and (3) attorney fees and court costs were improper because Broadview Heights did not engage in bad faith. View "State ex rel. Fluty v. Raiff" on Justia Law

The Supreme Court denied a writ of mandamus sought by the Board of Education of the Ottawa Hills Local School District ordering the Lucas County Board of Elections to place a tax levy on the November 7, 2023 general election ballot, holding that the Board of Elections did not abuse its discretion or act in disregard of applicable legal provisions when it refused to place the levy on the ballot.On August 28, 2023, the Board of Education brought this original action seeking a writ of mandamus ordering the Board of Elections to certify the levy at issue and place it on the November 2023 general election ballot. The Supreme Court denied the writ, holding (1) the Board of Education failed to certify an accurate resolution to proceed to the Board of Elections "not later than four p.m. of the ninetieth day before the day of the election," as required by Ohio Rev. Code 35.01.02(F); and (2) the Board of Education's error was not a technical violation that did not affect the public interest. View "State ex rel. Ottawa Hills Local School District Bd. of Education v. Lucas County Bd. of Elections" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing this complaint brought by Appellant requesting a writ of mandamus to compel the City of Mentor to commence appropriation proceedings for an alleged taking of Appellant's property, holding that the court of appeals did not err in granting the City's motion to dismiss.Appellant brought this complaint alleging that the decision of the City to deny a permit that would allow him to place a houseboat on a pond that he owned constituted a taking of his property. The court of appeals granted the City's motion to dismiss for failure to state a claim upon which relief could be granted and for lack of subject-matter jurisdiction, holding (1) Appellant had an adequate remedy in the ordinary course of the law and was not entitled to a writ of mandamus to compel the City to commence appropriation proceedings; and (2) the court of appeals lacked subject-matter jurisdiction over Appellant's remaining claims. View "State ex rel. Duncan v. Mentor" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting the trial court's motion to dismiss this complaint brought by Appellant seeking an order requiring the trial court to issue a final, appealable order regarding two criminal convictions, holding that the court of appeals did not err.Appellant, who pleaded guilty to the lesser offenses of gross sexual imposition and burglary, brought a complaint for a writ of mandamus alleging that because there was no entry that disposed of the original charges of rape and aggravated burglary, no final, appealable order had been issued, and seeking a final appealable order that complied with Crim.R. 32(C). The court of appeals dismissed the action. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law, and therefore, he was not entitled to relief in mandamus. View "State ex rel. Mitchell v. Pittman" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus sought by Appellant to compelling the Clark County Prosecuting Attorney to join in the filing of a motion to vacate guilty pleas Appellant had entered in two criminal cases, holding that Appellant's claim was not cognizable in mandamus.In his writ of mandamus, Appellant sought to compel the Clark County prosecuting attorney to join in the filing of a motion to vacate the guilty pleas that Appellant entered in two criminal cases. The court of appeals denied the writ on the grounds that Appellant had adequate remedies in the ordinary course of the law and that his claim was barred under the doctrine of res judicata. The Supreme Court affirmed on different grounds, holding that Appellant's claim seeking to enforce an alleged contractual duty was not cognizable in mandamus. View "State ex rel. Duncan v. Driscoll" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting in part and denying in part a writ of mandamus, affirmed the court's award of statutory damages and court costs, and reversed the award of attorney fees, holding that the court of appeals erred in determining that the City of Cleveland acted in bad faith in this case.Cleveland Association of Rescue Employees and its president (collectively, the Union) submitted two public records requests to the City, which denied the requests. The Union then filed a complaint for writ of mandamus to compel production of the records and also sought statutory damages and attorney fees for the City's alleged violation of Ohio Rev. Code 149.43(B). The Union later notified the court of appeals that the City had sufficiently produced the requested records and sought summary judgment with respect to statutory damages and attorney fees. The court of appeals awarded the Union statutory damages of $1,000 and attorney fees of $4,672. The Supreme Court reversed in part, holding that the City's refusal to accept a certified-mail service of the complaint was not a legitimate basis on which to award attorney fees. View "State ex rel. Cleveland Ass'n of Rescue Employees v. City of Cleveland" on Justia Law

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