Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court reversed the judgment of the court of appeals determining that Karen Michael held an equitable lien on David Miller's Ram Sensors, Inc. stock shares securing David's current obligation to pay monthly spousal support to Karen, holding that an equitable lien did not exist on the stock to secure the current obligation.When Karen and David divorced, the separation agreement incorporated into their final judgment entry of divorce provided that David would pay Karen $15,000 per month in spousal support for twenty years. Karen agreed to relinquish all rights she may have had in Ram Sensors, and David agreed to secure his spousal support obligations. Later, Karen filed a postdecree pleading against David and Cody seeking a declaration that David's ownership of the Ram Sensors stock secured his obligations under the divorce decree and requesting that the court order Cody Miller, the parties' son, to transfer David's stock to her. The court granted partial summary judgment to Karen, concluding that she held a perfected lien in the Ram Sensors stock and an equitable lien on the stock. The court of appeals affirmed. The Supreme Court reversed, holding that the court of appeals misconstrued the separation agreement and erred when it recognized an equitable lien securing David's current support obligation. View "Michael v. Miller" on Justia Law

The Supreme Court held that the compensatory-damages caps for noneconomic loss in Ohio Rev. Code 2315.18 were unconstitutionally applied to Plaintiff, who was sexually abused by Defendant when she was a child.A jury found Defendant guilty of over ninety counts of, among other things, rape and kidnapping. Thirty-four of those counts involved acts against Plaintiff. Plaintiff later filed a tort action against Defendant and asked the trial court for a declaratory judgment holding that section 2315.18 was unconstitutional as applied to her case. The jury awarded Plaintiff, inter alia, $20 million in compensatory damages for the abuse she suffered after the damages caps went in effect. The trial court denied Plaintiff's request for declaratory relief and reduced her $20 million noneconomic damages award to $250,000. The court reversed, holding that section 2315.18 is unconstitutional as applied to Plaintiff to the extent that it failed to include an exception to its compensatory-damages caps for noneconomic loss for plaintiffs who have suffered permanent and severe psychological injuries. View "Brandt v. Pompa" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals determining that Ohio Rev. Code 2152.84(A)(2)(b) was fundamentally unfair as applied to D.R., the juvenile in this case, and thus violated his right to procedural due process, holding that the court of appeals did not err.D.R. was adjudicated delinquent for sexually assaulting his friend when he was sixteen years old. The juvenile court suspended D.R.'s commitment and placed him on probation with conditions. The court classified D.R. as a Tier I offender and notified him that he had a duty to register as a sex offender. At the end of D.R.'s disposition, the magistrate terminated D.R.'s probation but continued his Tier I classification on the grounds that it lacked the statutory authority the terminate the classification. The court of appeals reversed. The Supreme Court affirmed, holding that the statute was fundamentally unfair as applied to D.R. and violated due process. View "In re D.R." on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court denying Defendant's motion to withdraw his guilty plea, holding that Defendant had a reasonable and legitimate basis to withdraw his guilty plea.Pursuant to a plea deal from the state, Defendant pleaded guilty to involuntary manslaughter. Defendant subsequently filed a motion to withdraw his guilty plea, asserting that his attorneys did not review all the discovery with him. The trial court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) a defendant has a reasonable and legitimate basis to withdraw his guilty plea when, before sentencing, he discovers evidence that his attorney withheld from him and that would have negated his decision to plead guilty had he known about it; and (2) the trial court erred by not granting Defendant's motion to withdraw his guilty plea. View "State v. Barnes" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for three abduction charges, holding that the State erred in failing to provide Defendant with a bill of particulars in this case.Defendant was indicted for the abduction of his grandchildren who lives and stayed with him after his unmarried daughter died. Defendant requested a bill of particulars to understand how his actions constituted the offense of abduction. The State, however, refused to provide one, and twice the trial court refused to compel the State to provide one. The Supreme Court vacated Defendant's conviction, holding that the State fell short of what is required under the Constitution by not giving Defendant notice of exactly what it was alleging he did that could have constituted the offenses charged. View "State v. Haynes" on Justia Law

The Supreme Court held that if an offender who is on community control is convicted and imprisoned for a new offense, the revocation proceeding in the original case may not result in a prison sentence that runs consecutively to the new prison sentence if no mention was made of consecutive sentences as part of the original sentence for community control.Defendant pled guilty in Harrison County to endangering children. The trial court sentenced her to five years of community control with a two-year prison sentence reserved. Later, the trial court revoked Defendant's community control based on Defendant's conviction for robbery in a Jefferson County case, for which she had received a term of three years' imprisonment. The trial court ordered Defendant to serve the reserved two-year sentence consecutively to the three-year sentence imposed in the Jefferson County case. The court of appeals vacated the sentence. The Supreme Court affirmed, holding that the trial court was not authorized to impose a consecutive prison term on Defendant because she was not advised that if she violated the terms of her community control, she might be ordered to serve the two-year reserved prison term consecutively to any other sentences. View "State v. Jones" on Justia Law

The Supreme Court granted in part and denied in part a writ of mandamus requested by Relator, an inmate at the Trumbull Correctional Institution, against Respondents, including Anthony Davis, (collectively, TCI) seeking production of records responsive to six public-records requests he sent in June 2021, holding that Relator was entitled, in part, to mandamus.By way of six messages, Relator requested four records. As to the first record, the Supreme Court denied mandamus on the ground that Relator failed to establish that Davis was the custodian of the record in question. As to the remaining three requested records, the Supreme Court held that TCI breached a statutory obligation to provide Relator with the records. The Court then awarded Relator $3,000 in statutory damages, holding that Relator satisfied the method-of-transmission requirement for an award of statutory damages. View "State ex rel. Ware v. Wine" on Justia Law