Justia Ohio Supreme Court Opinion Summaries

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

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