Justia Ohio Supreme Court Opinion Summaries

The Supreme Court held that Ohio Rev. Code 2929.14(C)(4) requires trial courts to consider the overall number of consecutive sentences and the aggregate sentence to be imposed when making the necessity and proportionality findings required for the imposition of consecutive sentences and that appellate review of consecutive sentences under Ohio Rev. Code 2953.08(G)(2) does not require deference to the trial court's findings under section 2929.14(C)(4).At issue was whether Defendant's sixty-five-year aggregate sentence for numerous nonviolent felonies violated section 2929.14(C)(4), Ohio's consecutive sentencing statute, or the Eighth Amendment to the United States Constitution. The Supreme Court reversed the court of appeals' judgment affirming Defendant's sixty-five year sentence and remanded the case for further consideration in light of the Court's clarification on how sections 2929.14(C)(4) and 2953.08(G)(2) are to be applied, holding (1) consecutive sentence findings must be made in consideration of the aggregate term to be imposed; and (2) appellate review of consecutive sentences does not require appellate courts to defer to the sentencing court's findings. View "State v. Gwynne" on Justia Law

The Supreme Court held that Defendant's sentence constituted cruel and unusual punishment under the Eighth and Fourteenth Amendments to the United States Constitution and Ohio Const. art. I, 9 when he was convicted as a juvenile and the trial court failed to consider his youth as a mitigating factor in sentencing.Defendant was charged with allegedly committing acts which, if committed by an adult, would constitute the offense of complicity to aggravated murder and other crimes. After a jury trial, Defendant was found guilty of several charges, and the trial court sentenced him to an indefinite life sentence in prison with parole eligible after thirty-eight to forty-three years. The Supreme Court reversed, holding that the trial court's sentence was unconstitutional because the court failed to consider Defendant's youth as a factor in sentencing. View "State v. Morris" on Justia Law

The Supreme Court reversed the portion of the judgment of the court of appeals affirming Appellant's conviction on count twenty-nine of the indictment and vacated that conviction and affirmed the portion of the judgment affirming Defendant's convictions on counts eleven, twenty, forty-five, forty-six, and fifty-five of the indictment, holding that, based on State v. Smith, 194 N.E.3d 197 (Ohio 2022), the adult court lacked subject matter jurisdiction over count twenty-nine.In Smith, the Supreme Court held that a finding of probable cause is a jurisdictional prerequisite under Ohio Rev. Code 215.212 to transferring a child to adult court for prosecution. In the instant case, Appellant argued that the adult court lacked subject-matter jurisdiction over count twenty-nine of the indictment because the juvenile court did not find probable cause to believe that Appellant had committed the act charged in that count. The Supreme Court agreed and reversed the court of appeals' decision affirming Appellant's conviction on count twenty-nine and otherwise affirmed, holding that Appellant's remaining claims of error were without merit. View "State v. Burns" on Justia Law

The Supreme Court affirmed the judgment of court of appeals denying a writ of mandamus sought by Waste Management of Ohio, Inc. ordering the Industrial Commission of Ohio to reverse its decision granting T.A.'s application for benefits, holding that the Commission did not abuse its discretion.Travis Gelhausen died shortly after getting into an accident while driving a truck for Waste Management of Ohio, Inc. T.A. applied for benefits on behalf of her and Gelhausen's minor daughter, S.G., for Gelhausen's loss of the use of his arms and legs before his death. The Commission granted the application. Waste Management sought a writ of mandamus ordering the Commission either to vacate its award or to limit the award. The court of appeals denied the writ. The Supreme Court affirmed, holding that the Commission's award was proper. View "State ex rel. Waste Management of Ohio, Inc. v. Industrial Commission" on Justia Law

The Supreme Court reversed the opinion of the the court of appeals affirming the trial court's denial of Defendant's motion to suppress evidence recovered as a result of a constitutionally-defective search warrant, holding that the good-faith exception to the exclusionary rule did not apply to the search of cell phones in this case.At issue was a constitutionally-deficient search warrant authorizing the search of cell phones found at the scene of a car crash. Nothing in the affidavit connected the cell phones to the accident except a police officer's averment that evidence of how the accident occurred may be found on the phones. The court of appeals affirmed the denial of Defendant's motion to suppress for lack of probable cause, upholding the cell-phone search under the good faith exception to the exclusionary rule. The Supreme Court reversed, holding (1) the warrant was constitutionally defective for want of probable cause in the warrant's supporting affidavit; and (2) the good-faith exception to the exclusionary rule did not apply. View "State v. Schubert" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals affirming the order of the trial court granting summary judgment in favor of the Rootstown Township Board of Trustees and dismissing Appellant's claims that the Board violated the Open Meetings Act (OMA), Ohio Rev. Code 121.22, holding that there was a minor error in the injunction issued by the trial court.At issue before the Supreme Court was the injunctive and civil-forfeiture remedies a trial court must order when it finds multiple violations of a single provision of section 121.22(I). The court of appeals in this case held that the Board violated the OMA at multiple meetings. On remand, the trial court entered summary judgment in favor of Appellant and issued injunctive relief prohibiting such conduct in the future and ordering the Board to pay two civil forfeiture penalties. The Supreme Court affirmed in part and reversed in part, holding that when repeated conduct results in multiple violations of a single provision of Ohio Rev. Code 121.22, the trial court may issue a single injunction ordering the public body to pay a single $500 civil forfeiture penalty as to all offenses. View "Ames v. Rootstown Township Bd. of Trustees" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that use and development and alienation restrictions in a deed applied to both the surface and subsurface of the properties at issue in this case and that the village of Barnesville violated the restrictions when it transferred oil and gas rights to another entity without obtaining written permission from Ohio Public Works Commission (OPWC), holding that there was no error.The village received two grants to finance the purchase of two properties for conservation projects. The OPWC brought this action claiming that the village violated transfer and use restrictions in the deeds for the properties at issue by transferring oil and gas rights to another entity, which leased those rights to Gulfport Energy Corporation, without obtaining the OPWC's permission. The court of appeals granted judgment in favor of OPWC. The Supreme Court affirmed, holding that the court of appeals correctly determined that the village violated the use and development restrictions when it transferred oil and gas rights without OPWC's written consent. View "Ohio Public Works Commission v. Village of Barnesville" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court granting summary judgment for employees of a children's services agency and dismissing the wrongful death action against them, holding that genuine issues of material fact existed, barring summary judgment.Appellant, the grandmother of Harmony Carsey, who was two years old when she died at her mother's home, brought a wrongful death action against employees of Perry County Children's Services (Appellees). Appellees moved for summary judgment, arguing that as children's services workers, they were immune from liability because they had not acted recklessly or wantonly or violated their duty of care. The trial court granted the motion, concluding that Appellees were immune from liability. The court of appeals affirmed. The Supreme Court reversed, holding that there were genuine issues of material fact as to whether the conduct of one or more of the agency employees was reckless or wanton. View "Smathers v. Glass" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals ruling that the state's rebuttal of a defendant's claim of self-defense is not subject to review under the sufficiency-of-the-evidence standard, holding that the state's new burden of disproving the defendant's self-defense claim beyond a reasonable doubt is subject to a manifest-weight review on appeal.After a jury trial, Defendant was convicted of murder and felony murder and sentenced to eighteen years to life in prison. On appeal, Defendant argued that the state had not presented legally sufficient evidence to establish that he had not acted in self-defense and that the state had failed to disprove self-defense under a "manifest weight" standard. The court of appeals rejected Defendant's claims and affirmed. The Supreme Court affirmed, holding (1) the 2018 Am.Sub.H.B. No. 228 amendments to Ohio Rev. Code 2901.05 did not eliminate Defendant's burden of production regarding a claim of self-defense; (2) the state's new burden of disproving a self-defense claim beyond a reasonable doubt is subject to a manifest-weight review on appeal; and (3) the court of appeals did not err in declining to review the state's rebuttal of self-defense for sufficiency of the evidence. View "State v. Messenger" on Justia Law

The Supreme Court reversed the judgment of the court of appeals finding that the trial court did not abuse its discretion by denying Defendant's request to enter a plea of no contest on the ground that the court did not believe there were any legitimate issues to raise on appeal, holding that the trial court abused its discretion.Defendant was indicted on five drug-related counts. Defendant informed the court that he wished to proceed with a no-contest plea, but the trial court denied Defendant's request on the ground that there was no legitimate issue for appeal. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court abused its discretion by denying Defendant's request to enter a no-contest plea based on its own review of the appealable issues. View "State v. Hill" on Justia Law