Justia Ohio Supreme Court Opinion Summaries

The Supreme Court granted a writ of mandamus ordering the City of East Cleveland to satisfy a civil judgment against it won by Marilyn Conard and Charles Hunt, plus pre- and post-judgment interest, or to take steps set forth in Ohio Rev. Code 1744.06(A) for appropriating the funds necessary to satisfy the judgment, holding that mandamus relief was warranted.Conard and Hunt sued the City for injuries they received after a police vehicle collided with their vehicle. A jury returned a verdict in favor of Hunt and Conard and entered a separate order awarding prejudgment interest. Hunt and the administrator of the estate of Conard later commenced this action seeking a writ of mandamus ordering the City to satisfy the judgment. The Supreme Court granted the writ, holding that section 2744.06(A) imposed a clear legal duty on the City to satisfy the judgment rendered in favor of Hunt and Conard. View "State ex rel. Hunt v. City of East Cleveland" on Justia Law

The Supreme Court affirmed Appellant's complaint for a writ of prohibition to prevent Cuyahoga County Common Pleas Court Judge Deena Calabrese from exercising jurisdiction in the underlying matter brought to enforce a divorce decree, holding that the court of appeals properly dismissed the complaint for failure to state a claim.In 2016, the divorce decree at issue was entered dissolving the marriage of Neil and Erica Heyside. Erica later sued Neil in the general division of the common pleas court alleging that Neil owed her thousands of dollars in spousal support and seeking to enforce the property division under the decree. Neil filed a motion to dismiss, which the trial court denied. Neil then filed a complaint for a writ of prohibition seeking to have Judge Calabrese barred from continuing to exercise judicial power over Erica's lawsuit. The court of appeals dismissed the complaint for failure to state a claim. The Supreme Court affirmed, holding that that the general division of the common pleas court did not patently or unambiguously lack jurisdiction over Erica's lawsuit. View "State ex rel. Heyside v. Calabrese" 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 North Central Correctional Complex, where Appellant was an inmate, holding that the court of appeals properly denied Appellant relief in habeas corpus.In his petition for a writ of habeas corpus, Appellant sought immediate release from prison, arguing that he was unlawfully detained because he had fully served his sentences. The court of appeals granted summary judgment in favor of the warden. The Supreme Court affirmed, holding that the court of appeals correctly found that Appellant's maximum sentence had not expired. View "State ex rel. Jackson v. Watson" on Justia Law

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