Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals holding that the failure to have satisfied a condition of community control prevents a defendant from receiving a final discharge even after community control has been terminated, holding that the court of appeals erred.At issue was the point at which a defendant convicted of a felony attains a "final discharge" from a sentence of nonresidential community control for purposes of becoming eligible to apply to have the felony conviction sealed. The court of appeals concluded that the conditions of a defendant's nonresidential community-control sanction constitute sentencing requirements and that a defendant must satisfy all such requirements in order to receive a final discharge. The Supreme Court reversed, holding that when a defendant's nonresidential community control is terminated the defendant receives a final discharge from the community-control sanction. View "State v. P.J.F." on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's convictions and remanding the matter for a new trial, holding that the trial court did not violate Defendant's Sixth Amendment right to a public trial by partially limiting access to the courtroom after an altercation disrupted court proceedings.Defendant was indicted on two counts of murder. During a recess on the third day of trial, some of the people attending the trial were involved in an altercation outside the courtroom, which resulted in the court limiting attendees to only immediate family members. Defendant was subsequently found guilty of murder as a result of felonious assault. The court of appeals reversed, ruling that the trial court had committed structural error by failing to provide sufficient justification for the partial closure of the courtroom. The Supreme Court reversed, holding that a public trial violation occurred in Defendant's trial but that the error did not rise to the level of a plain error that must be corrected. View "State v. Bond" on Justia Law

The Supreme Court reversed in part the decision of the Board of Tax Appeals (BTA) affirming a final assessment imposed by the tax commissioner determining that NASCAR owed taxes, interest, and penalties in the amount of $549,520, holding that the bulk of the tax assessment was unlawful.The Ohio Department of Taxation conducted an audit and determining that NASCAR had improperly failed to pay Ohio's commercial-activity tax (CAT), Ohio Rev. Code 5751.91 et seq., from 2005 to 2010 and owed Ohio more than in back taxes and penalties. The BTA affirmed the assessment, determining that for the four revenue streams under review - broadcast, media, licensing, and sponsorship - the receipts were properly situated to Ohio. NASCAR appealed, arguing that its broadcast revenue, media revenue, licensing revenue, and sponsorship revenue were not subject to the CAT. The Supreme Court reversed the tax assessment as to NASCAR's broadcast revenue, media revenue, licensing fees, and sponsorship fees, holding (1) the broadcast revenue was not based on the right to use NASCAR's property in Ohio; and (2) the media revenue, licensing fees, and sponsorship fees situated to Ohio were not "based on the right to use" NASCAR's property in Ohio. View "NASCAR Holdings, Inc. v. McClain" on Justia Law

The Supreme Court reversed the decision of the court of appeals determining that one need not be prejudiced to be an "adversely affected" party, as that phrase is used in Ohio Rev. Code 119.12(I), holding that the phrase "adversely affected" as used in the statute imposes a prejudice requirement.After the State Personnel Board of Review ordered that Kristy Goudy be reinstated to her position at the Tuscarawas County Public Defender's Office, the public defender's office appealed. The personnel board, however, failed timely to certify a complete record. It subsequently corrected the error and certified the remainder of the record outside the allotted time. The court of common pleas ruled that the public defender's office was not an adversely affected party because the delay in certifying the record did not cause any prejudice to the office. The court of appeals reversed. The Supreme Court reversed, holding (1) the court of appeals erred in concluding that section 119.12(I) does not contain a prejudice requirement; and (2) prejudice was not shown in this case. View "Goudy v. Tuscarawas County Public Defender" on Justia Law

The Supreme Court reversed the judgment of the court of appeals granting a writ of mandamus ordering the Industrial Commission of Ohio to reverse its decision awarding Appellant temporary-total-disability (TTD) compensation after sustaining a work injury, holding that the Commission's order was neither unsupported by evidence in the record nor was it contrary to law.Appellant gave Appellee two weeks' notice of her intention to resign and subsequently sustained a work injury. The Commission awarded Appellant TTD compensation. The court of appeals granted a writ ordering the Commission to reverse its decision because Appellant had resigned from her employment prior to her injury. Relying on the Supreme Court's opinion in State ex rel. Klein v. Precision Excavating & Grading Co., 119 N.E.3d 386 (Ohio 2018), the court of appeals granted the writ. The Supreme Court reversed, holding (1) the decision in Klein did not redefine voluntary abandonment of the workforce as voluntary abandonment of the injured worker's position; and (2) the Commission did not abuse its discretion in determining that, but for her work injury, Appellant would have remained gainfully employed. View "State ex rel. Ohio State University v. Pratt" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court denying Appellant's motion for leave to file a motion for a new trial and a successive petition for postconviction relief without an evidentiary hearing, holding that the lower courts abused their discretion by applying res judicata to preclude Appellant's claims.In 1997, Appellant was convicted of aggravated burglary, kidnapping, rape, felonious assault, and theft. In 2018, Appellant discovered a memorandum that led him to file a motion for leave to file a motion for a new trial and a successive petition for postconviction relief. The trial court denied relief, concluding that res judicata barred Appellant's arguments because the memo was "not really new" evidence. The court of appeals affirmed. The Supreme Court reversed, holding that res judicata did not bar Appellant's motion or his petition. View "State v. Hatton" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against Baker, Dublikar, Beck, Wiley & Mathews (the Baker firm), Public Entity Risk Services of Ohio (PERSO), and the Ohio Township Association Risk Management Authority (OTARMA) seeking to obtain unreacted copies of invoices that the Baker firm had prepared for PERSO, holding that the court of appeals did not properly apply the standard of review in dismissing Appellant's petition.Appellant brought this action under Ohio's Public Records Act, Ohio Rev. Code 149.43, seeking a writ of mandamus ordering Appellees to produce unreacted copies of the requested records. The court of appeals determined that Appellees were subject to the Act despite their private-party status but dismissed the petition on the ground that the records were protected by the attorney-client privilege. The Supreme Court reversed, holding (1) PERSO was not immune from suit; and (2) the court of appeals department from the Civ.R. 12(B)(6) standard. View "State ex rel. Ames v. Dublikar, Beck, Wiley & Mathews" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Appellant's petitions for postconviction relief challenging his convictions in a rape case and a jail case, holding that there was no error.After a jury trial, Appellant was convicted of rape and kidnapping. While he was being held in jail on the rape charges, Appellant and two other inmates attacked one of their cellmates. A jury found Appellant guilty of felonious assault and kidnapping for the attack. Appellant later filed petitions for postconviction relief challenging his convictions in both cases. The trial court denied relief. The Supreme Court affirmed, holding (1) postconviction claims alleging a denial of the constitutional right to effective assistance of counsel are not procedurally barred if they cannot meaningfully be reviewed without resorting to evidence outside the trial record; and (2) all of Appellant's claims were either barred by res judicata or failed to set forth a substantive claim for relief. View "State v. Blanton" on Justia Law

The Supreme Court denied Petitioner's petition for a writ of habeas corpus against the warden of the Richland Correctional Institution, holding that Petitioner failed to attach his commitment papers, as required by Ohio Rev. Code 2725.04(D).Petitioner, an inmate at the institution, was serving a sentence for aggravated murder and other felonies. In his petition for a writ of habeas corpus Petitioner argued that the failure to accord him a parole hearing as required under the original sentencing entry. In his returned, the warden argued that the writ should be denied because Petitioner did not comply with section 2725.04(D). The Supreme Court agreed and denied the writ, holding that that affidavit attached to Petitioner's habeas petition did not offer a legitimate justification for Petitioner's failure to comply with section 2725.04(D). View "McDonald v. Black" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint seeking an order prohibiting the general division judge from exercising further authority over some of the claims in the underlying case, holding that the court of appeals properly dismissed the complaint.Appellant brought an action against the estate of his ex-wife in the general division of the court of common pleas seeking to recover funds to which Appellant claimed he was entitled under the former spouses' separation agreement. The state filed a counterclaim against Appellant. The trial court ruled (1) Appellant was entitled to $15,353, but there were genuine issues that precluded summary judgment on his remaining claims; and (2) the estate was entitled to partial summary judgment on its counterclaims. Appellant then filed a complaint for a writ of prohibition seeking to prevent the judge from taking further action on the estate's counterclaim. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that the general division did not patently or unambiguously lack subject-matter jurisdiction, and Appellant had an adequate legal remedy by way of direct appeal. View "State ex rel. Gray v. Kimbler" on Justia Law