Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that the court of appeals correctly dismissed Appellant's petition.Appellant, an inmate at the Trumbull Correctional Institution, filed this petition for a writ of habeas corpus in 2021 seeking his immediate release from prison and alleging that he had completed his original sentence in 2020 and was being wrongfully imprisoned for his 1998 conviction. The court of appeals dismissed the petition because, among other things, Appellant's petition did not comply with Ohio Rev. Code 2969.25(A). The Supreme Court affirmed, holding that Appellant's failure to comply with section 2969.25(A) warranted dismissal. View "Alston v. Bracy" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court rejecting Defendant's amended petition for postconviction relief without holding a hearing, holding that the trial court erred in failing to hold an evidentiary hearing before reaching its decision.Defendant was convicted of rape, kidnapping, and other offenses. In his amended petition for postconviction relief Defendant asserted that his trial counsel had been ineffective for failing to present expert testimony to assist the jury in understanding the unreliability of eyewitness identification, particularly under the circumstances of this case. The trial court denied relief without holding a hearing. The Supreme Court reversed and remanded the case, holding that Defendant's ineffective assistance claim presented an issue that the trial court needed to examine at an evidentiary hearing before ruling on the claim. View "State v. Bunch" on Justia Law

In this dispute over whether Ohio Power Company, a private agency authorized to appropriate property under Ohio Rev. Code 163.01(B) and (C), was entitled to any of the necessary presumptions set forth in Ohio Rev. Code 163.09(B)(1) in establishing the necessity of easements through eminent domain to upgrade electric transmission lines, the Supreme Court held that the court of appeals properly reversed the trial court's determination that the appropriations at issue were necessary.Specifically, the Supreme Court held (1) the term "appropriation" in Ohio Rev. Code 163.09(B)(1) means the appropriation of the "parcel or contiguous parcels in a single common ownership, or interest or right therein," as identified in the petition filed by an agency under Ohio Rev. Code 163.05; (2) because neither Ohio Power's board of directors nor the Ohio Siting Board reviewed the appropriations Ohio Power was not entitled to a rebuttable presumption under section 163.09(B)(1)(a) or an irrebuttable presumption under section 163.09(B)(1)(c); and (3) Ohio Power was entitled to a rebuttable presumption under section 163.09(B)(1)(b) because it provided evidence of the necessity for the appropriations. The Court remanded this case for further proceedings. View "Ohio Power Co. v. Burns" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the trial court declining to declare Plaintiff a wrongfully imprisoned person, holding that the court of appeals did not err in concluding that Plaintiff was not entitled to a jury trial for his wrongful imprisonment claims.Plaintiff brought this action against the state of Ohio to be declared a "wrongly imprisoned individual" under Ohio Rev. Code 2743.48(A). Plaintiff included a jury demand with his complaint, but the trial court overruled the demand. After a bench trial, the trial court entered judgment for the state. The court of appeals affirmed, ruling that Plaintiff did not have a constitutional right to a jury trial in the wrongful-imprisonment action. The Supreme Court affirmed, holding that the constitutional right to a jury trial does not attach to wrongful imprisonment actions. View "McClain v. State" on Justia Law

In this case involving a dispute about a statute that sets forth the requirements a firm must meet to provide engineering services in the state of Ohio the Supreme Court held that there is nothing in the statutory language of Ohio Rev. Code 4733.16(D) to preclude an independent contractor from serving as a full-time manager of an engineering firm.Section 4733.16(D) provides that an engineering firm must designate one or more full-time partners, managers, members, officers, or directors as in "responsible charge" of its engineering activities. The Ohio Board of Registration for Professional Engineers and Surveyors denied TWISM Enterprises, LLC a certificate of authorization to provide engineering services, adopting a hardline rule that section 4733.16(D) requires formal W-2 employment. The court of appeals upheld the determination. The Supreme Court reversed, holding that TWISM met the requirements for a certificate of authorization to practice engineering. View "TWISM Enterprises, LLC v. State Bd. of Registration for Professional Engineers & Surveyors" on Justia Law

The Supreme Court held that the payment of a civil fine for a traffic violation under a city's automated traffic enforcement program without a dispute of liability for the violation precludes those improperly ticketed under the program from raising an unjust enrichment claim against the city in a separate action.Appellees - Plaintiffs in a class action - were vehicle lessees who received tickets under the city of the city of Cleveland's automated traffic enforcement program. Plaintiffs did not appeal their cases, and most paid the civil fine. The trial court granted Appellees' motion for class certification. The City appealed, arguing that res judicata precluded class relief. After the court of appeals affirmed the class certification order the trial court ruled in favor of the class. The Supreme Court reversed, holding that by paying their civil fines and not disputing their liability, Appellees admitted their liability for their traffic violations, and res judicata prevented a subsequent lawsuit. View "Lycan v. City of Cleveland" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the order of the trial court granting restitution to the victims of Defendant's theft, holding that, although the victims should be compensated for the loss of their stolen vehicle, they did not act to protect their right to restitution when they did not appeal the portion of Defendant's sentence denying restitution.Defendant pleaded guilty to grand theft of the victims' motor vehicle. The trial court sentenced Defendant to eighteen months in prison. Five months later, the victims filed a complaint for a writ of mandamus seeking an order to compel the trial court to hold a restitution hearing. The court of appeals granted summary judgment in favor of the victims and ordered the trial court to hold a restitution hearing. The trial court held a hearing and entered a restitution order for $1,976.55. The court of appeals concluded that the trial court's supplemental sentencing entry ordering restitution was void because the trial court lost jurisdiction to modify restitution when Defendant was released from prison. The Supreme Court affirmed, holding that the trial court lost any jurisdiction to modify the sentence when Defendant completed his sentence. View "State v. Brasher" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the trial court's denial of Greenville's motion to dismiss this tort case, holding that Plaintiffs alleged sufficient facts that, if proven, demonstrate that Ohio Rev. Code 2744.02(B)(4) applied to the facts of this case.At issue was whether the absence of a fire extinguisher within a building of a physical subdivision is a physical defect such that an exception to immunity exists under Ohio Rev. Code 2744.04(B)(4). Plaintiffs filed a complaint against Greenville City Schools and other defendants (collectively, Greenville) alleging that Greenville negligently caused their injuries after a bottle of isopropyl alcohol caught fire and exploded in a science class. Greenville filed a motion to dismiss, arguing that it was immune from liability and that no exception to immunity applied. The trial court denied the motion to dismiss, and the court of appeals affirmed. The Supreme Court affirmed, holding that the absence of a fire extinguisher or other safety equipment within a science classroom could be a physical defect such that an exception to immunity could exist under section 2744.02(B)(4). View "Doe v. Greenville City Schools" on Justia Law

The Supreme Court reversed the judgment of the court of appeals and reinstated the trial court's grant of summary judgment in favor of Owners Insurance Co. on EMOI Services, LLC's claim of breach of contract and bad-faith denial of insurance coverage after a ransomware attack on EMOI's computer-software systems, holding that Owners was not responsible for covering the loss at issue.At issue was whether the businessowners insurance policy issued by Appellant to EMOI covered losses suffered by EMOI when it became the target of a ransomware attack. The trial court granted summary judgment to Owners. The court of appeals reversed, concluding that genuine issues of material fact precluded summary judgment. The Supreme Court reversed, holding that Owners did not breach its contract with EMOI because the pertinent insurance policy did not cover the type of loss EMOI experienced. View "EMOI Services LLC v. Owners Insurance Co." on Justia Law

The Supreme Court held that a three-year prison term imposed under Ohio Rev. Code 2950.99(A)(2)(b) is to be imposed "in addition to" any prison term imposed under "any other provision of law," including a sentence imposed under Ohio Rev. Code 2929.14(A)(3)(b).In 2013, Defendant was convicted of unlawful sexual conduct with a minor. In 2018, Defendant was convicted of failing to provide a change of address notification for his sex offender registration, in violation of Ohio Rev. Code 2950.05(F)(1), and sentenced to serve three years and nine months in prison. On appeal, Defendant argued that section 2929.14(A)(3)(b) limited his possible sentence for a thirty-degree felony to a maximum of thirty-six months. The court of appeal affirmed Defendant's sentence. The Supreme Court affirmed, holding that, under the unambiguous language of section 2950.99(A)(2)(b), a trial court must impose a three-year prison sentence "in addition to" the sanctions imposes under section 2929.14. View "State v. Ashcraft" on Justia Law