Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed in part the judgment of the court of appeals vacating the trial court's judgment finding Defendant guilty of various sex crimes and remanding the case for a new trial without the testimony of the state's expert witness, holding that Crim.R. 16(K) precludes an expert witness from testifying at a trial commencing fewer than twenty-one days after the disclosure of the expert's written report.On appeal, Defendant argued that the trial court erred in allowing Dr. Stuart Bassman, the state's expert witness, to testify when the state failed to provide Defendant's attorney with the expert's report until six days before trial. The court of appeals agreed and remanded the case for a new trial without Dr. Bassman's testimony. The Supreme Court reversed the portion of the court os appeals' judgment precluding Dr. Bassman's testimony but otherwise affirmed, holding that Crim.R. 16(K) precludes an expert witness from testifying only at the trial commencing fewer than twenty-one days after the required disclosure is made and does not preclude otherwise admissible expert testimony at a defendant’s retrial. View "State v. Bellamy" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated murder with death specifications and her sentence of death, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant raised sixteen propositions of law. The Supreme Court rejected each proposition of law, holding, among other things, that (1) there was no prejudicial error in the trial court's evidentiary rulings; (2) Defendant was not entitled to relief on his ineffective assistance of counsel claims; (3) although significant mitigating factors existed, the aggravating circumstances outweighed the mitigating factors beyond a reasonable doubt; and (4) the death sentence was appropriate and proportionate. View "State v. Drain" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against the Ohio Department of Rehabilitation and Correction (DRC), holding that the court of appeals correctly dismissed the petition for failure to state a claim upon which relief can be granted.Appellant was convicted of aggravated robbery with a firearm specification and sentenced to an aggregate prison term of ten years. Appellant later filed a petition for a writ of mandamus, arguing that he had completed his maximum sentence. The court of appeals dismissed the petition, seeing no need to correct DRC's sentence calculation. The Supreme Court affirmed, holding that the DRC correctly calculated what Appellant's aggregate sentence should be. View "State ex rel. Scott v. Ohio Dep't of Rehabilitation & Correction" 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 Appellant's petition was moot.Appellant pleaded no contest to several drug-related offenses and was sentenced to six years' imprisonment. Appellant later filed a petition for writ of habeas corpus, arguing that sentencing errors entitled him to immediate release. The court of appeals granted the warden's motion to dismiss under Civ.R. 12(B)(6) for failure to state a valid claim in relief. After he appealed, Appellant was released from prison. The Supreme Court affirmed the court of appeals' dismissal of the action, holding that Appellant's release from incarceration meant that his habeas claim was moot. View "State ex rel. Johnson v. Foley" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of disclosing confidential information in violation of Ohio Rev. Code 102.03(B), holding that a person who is subject to the jurisdiction of the Ohio Ethics Commission (Commission) may be criminally prosecuted for a violation of section 102.03(B) without the Commission first investigating or prosecuting the charge.Defendant, a sheriff, was found guilty of violating section 102.03(B), a provision of Ohio's ethics law, for posting confidential information on the website of the sheriff's office. At issue on appeal was whether a criminal prosecution may be brought alleging a violation of section 102.03(B) without a prior review of the charges by the Commission. The court of appeals held that the trial court properly refused to dismiss the charges against Defendant on these grounds. The Supreme Court affirmed, holding that prosecutions may be brought by a prosecuting authority before the Commission initiates or completes its investigation. View "State v. Towns" on Justia Law

The Supreme Court reversed the judgment of the court of appeals determining that the evidence should have been suppressed in the underlying criminal case based on a statutory violation, holding that there was no violation of Defendant's Fourth Amendment rights in this case.While Defendant was serving community control, his probation officer conducted a random home-check on Defendant, searched his cell phone, and discovered child pornography. Defendant moved to suppress the uncovered evidence on the grounds that the suspicion-less search violated the Fourth Amendment. The district court denied the suppression motion. The court of appeals reversed, concluding that the search violated Ohio Rev Code 2951.02(A)'s requirement that a probation officer may conduct a search only when there are "reasonable grounds to believe" that a probationer is violating the law or conditions of control. The Supreme Court reversed, holding (1) the probation officer exceeded the scope of her authority when she searched Defendant's cell phone without reasonable grounds to believe that he had violated the law or the conditions of probation; and (2) because there was no constitutional violation, there was no basis to exclude the evidence obtained as a result of the search. View "State v. Campbell" on Justia Law

The Supreme Court affirmed the judgment of the district court dismissing Appellant's mandamus complaint under Civ.R. 12(B)(6) for failure to state a claim upon which mandamus relief can be granted, holding that the court of appeals did not err or abuse its discretion.Appellant, an inmate, commenced this mandamus action alleging that the parole board erred in determining the date of his first eligibility for parole. DRC filed a motion to dismiss the complaint for failure to state a claim. The court of appeals granted the motion after noting that the crux of Appellant's argument was that his second parole hearing should take place four years earlier than currently scheduled because his initial parole hearing was four years too late. The Supreme Court affirmed, holding that the court of appeals correctly dismissed Appellant's complaint for failure to state a valid claim for mandamus relief. View "State ex rel. Shine v. Ohio Dep't of Rehabilitation & Correction" on Justia Law

The Supreme Court held that Defendant was properly sentenced for murder and that the failure of a sentencing entry to track precisely the language of the applicable criminal sentencing statutes does not render the sentence contrary to law.Defendant was convicted of murder and sentenced to "life in prison with eligibility [for] parole after 15 years." The sentencing entry, however, did not precisely track the language of the applicable criminal sentencing statute. The court of appeals vacated Defendant's murder sentence, concluding that the trial court's sentencing language regarding the murder count was dissimilar enough from the language of Ohio Rev. Code 2929.02(B)(1) to require vacation of that sentence and a remand for resentencing. The Supreme Court reversed in part, holding (1) whatever difference existed between the language of section 2929.02(B)(1) and the language in Defendant's sentencing entry, the difference was de minimis; and (2) Defendant's murder sentence complied with section 2929.02(B)(1). View "State v. Leegrand" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that prevailing parties who were awarded reasonable attorney fees and punitive damages in a tort case involving malicious conduct may not also recover the attorney fees that they incur in successfully defending their judgment, holding that the court of appeals erred.The trial court awarded the prevailing parties attorney fees and expenses, but the court of appeals reversed the trial court's decision regarding attorney fees. On remand, the prevailing parties moved to modify their motion for attorney fees to include a request for "fees incurred in appellate litigation." The court of appeals reversed the portion of the award of attorney fees for appellate work, concluding that Ohio law does not permit recovery of attorney fees incurred at the appellate level except when a remedial statute so provides. The Supreme Court reversed, holding that when parties are awarded punitive damages at trial, they may also recover reasonable attorney fees that they incur successfully defending their judgments on appeal. View "Cruz v. English Nanny & Governess School" on Justia Law

The Supreme Court denied a writ of mandamus sought by Brandon L. King, mayor of East Cleveland, to compel the Cuyahoga County Board of Elections to remove a recall election against King from the November 8, 2022 ballot, holding that King failed to establish that he was entitled to the writ.Charles Holmes delivered an affidavit to the clerk of the East Cleveland city council seeking to recall King from office. The clerk issued blank recall petitions to Holmes, who returned with part-partitions. The clerk concluded that the petition contained enough valid signatures to qualify for the ballot, and the Board ordered a recall election to appeal on the November 2022 general election ballot. Holmes subsequently brought a complaint for a writ of mandamus. The trial court denied the motion. The Supreme Court denied Darryl Moore's motion for leave to intervene and denied the writ of mandamus, holding (1) Moore was not entitled to intervene; and (2) the Board had no authority under the City of East Cleveland charter to decertify the King recall petition. View "State ex rel. King v. Cuyahoga County Bd. of Elections" on Justia Law