Justia Ohio Supreme Court Opinion Summaries

A limited partnership operating a timber farm in Monroe County, Ohio, purchased a Mercedes-Benz Geländewagen in 2018 for use on its rugged, 1,100-acre property, which is primarily forested. The farm, with a history dating back to 1902, had transitioned from fruit and dairy to timber production. The vehicle was acquired to facilitate forest management activities, including traversing difficult terrain to apply chemicals and equipment for the removal of invasive species, inspect timber, and support sustainable harvesting practices. The farm had not reported timber sales or income since 2011, but had invested in forest management and hired consultants to implement long-term plans for sustainable timber production.The Ohio Tax Commissioner issued a use-tax assessment on the vehicle, finding that the farm was not actively engaged in the business of farming due to the absence of recent sales or income, and that the vehicle was not used directly or primarily in farming activities. The Board of Tax Appeals affirmed the assessment, concluding that the vehicle was used mainly for transportation around the property rather than for direct farming purposes, and that the farm had not demonstrated the vehicle’s primary use was for farming.The Supreme Court of Ohio reviewed the case and reversed the Board of Tax Appeals’ decision. The court held that the statutory exemption for use tax on items used in farming does not require “direct” use, and that the farm’s activities—including forest management and preparation for future timber sales—constituted engagement in the business of farming. The court found that the vehicle was used in farming and primarily for that purpose, based on uncontradicted testimony. The case was remanded for cancellation of the tax assessment. View "Claugus Family Farm, L.P. v. Harris" on Justia Law

A company constructed and operated a large interstate natural gas pipeline running through Ohio, which was completed in late 2018. The project’s actual construction costs significantly exceeded initial estimates due to unusually heavy rainfall causing delays and an environmental incident that led to regulatory actions and further delays. During construction, an investment firm acquired a substantial indirect ownership interest in the pipeline’s parent company, paying a price that implied a high valuation for the pipeline.For the 2019 tax year, the Ohio Tax Commissioner assessed the taxable value of the Ohio portion of the pipeline using a statutory cost-based method, resulting in a valuation that the company believed was excessive. The company challenged the assessment, arguing that the pipeline’s true value was much lower, citing alternative appraisal methods and the impact of construction delays and overruns. The Tax Commissioner rejected these arguments, maintaining that the statutory method produced the correct value.The company appealed to the Ohio Board of Tax Appeals, where both parties presented expert appraisals. The company’s appraiser used a unit appraisal approach and arrived at a lower value, while the Tax Commissioner’s appraiser, using both cost and income approaches, opined a higher value. The Board found the Tax Commissioner’s appraisal more credible, especially in light of the investment firm’s transaction and the actual construction costs, and ordered the pipeline to be valued according to that appraisal.On further appeal, the Supreme Court of Ohio reviewed whether the Board’s decision was reasonable and lawful. The court held that the Board has broad discretion in weighing competing appraisals and evidence, and that its adoption of the Tax Commissioner’s appraisal was supported by the record. The court affirmed the Board’s decision, upholding the higher valuation for tax purposes. View "Rover Pipeline, L.L.C. v. Harris" on Justia Law

A man who had attended elementary school with a woman, but had never been friends or even acquaintances with her, began contacting her more than a decade later. The woman, A.P., posted on her public Instagram account for her 29th birthday, and the man, Dorian Crawl, commented with a “sad emoji” and a message expressing affection and a desire to meet. A.P. did not respond. Days later, Crawl commented again on another post, asking if the video showed her house. Less than a month after these online interactions, Crawl appeared uninvited at A.P.’s apartment, knocked on her door, identified himself as her “friend,” and turned the doorknob. A.P., frightened, locked the door, hid her daughter, and called the police. Crawl later admitted to police that he had found A.P.’s address online and continued to message her even after being confronted by law enforcement. A.P. testified that these events caused her significant anxiety and changes to her daily life.The Miamisburg Municipal Court found Crawl guilty of menacing by stalking under R.C. 2903.211(A)(1). On appeal, the Second District Court of Appeals affirmed the conviction, holding that Crawl’s pattern of conduct—including the social media messages and the uninvited visit—along with A.P.’s testimony about her mental distress, was sufficient to support the conviction.The Supreme Court of Ohio reviewed the case and affirmed the judgment of the Second District Court of Appeals. The court held that, when viewing the evidence in the light most favorable to the prosecution, a rational trier of fact could find that the essential elements of menacing by stalking were proven beyond a reasonable doubt. The court clarified that explicit threats, a prior relationship, or notice from the victim are not required to establish the offense. The court concluded that Crawl’s actions constituted a pattern of conduct, caused mental distress, and were done knowingly. View "State v. Crawl" on Justia Law

A resident of Lucas County, along with his nephews, was involved in a drug-selling enterprise known as the Tecumseh Street Gang, which operated primarily on the 800 block of Tecumseh Street in Toledo. The group was a subset of a larger gang, the Southside Gangster Disciples. Law enforcement, using a confidential informant, discovered that a woman named Armijo was distributing cocaine for the Tecumseh Street Gang. On several occasions, Armijo purchased cocaine from one of the nephews in Lucas County and then traveled to Henry County to resell the drugs. She often bought the drugs on credit, keeping a portion of the profits after paying the supplier.The defendant was charged in the Henry County Court of Common Pleas with engaging in a pattern of corrupt activity. At trial, he argued that venue was improper in Henry County because Armijo was not part of the same enterprise. The trial court denied his motion for acquittal, and the jury found him guilty, also finding that venue was proper. On appeal, the Third District Court of Appeals upheld the conviction, concluding that the evidence supported the finding that Armijo was associated with the same enterprise and that her activities in Henry County established proper venue.The Supreme Court of Ohio reviewed the case to determine whether venue in Henry County was appropriate for prosecuting the defendant under R.C. 2923.32. The court held that venue was proper in any county where a member of the enterprise conducted activity on behalf of the enterprise, even if the defendant himself did not act there. The court found sufficient evidence that Armijo was associated with the enterprise and that her drug sales in Henry County were part of its activities. The Supreme Court of Ohio affirmed the judgment of the Third District Court of Appeals. View "State v. Brown" on Justia Law

Lori Elmore and the City of Whitehall filed a protest against the candidacy of Holly Stein for the Ward 4 seat on the Whitehall City Council, arguing that Stein did not meet the two-year residency requirement specified in Section 3(a) of the Whitehall Charter. Stein had filed her declaration of candidacy in January 2025, but Elmore contended that Stein had not lived in Ward 4 for the two years immediately preceding the election, as required by the charter. Stein admitted to living outside Ward 4 in 2023 but argued that the charter only required her to have lived in Ward 4 for any two-year period before the election.The Franklin County Board of Elections held a hearing on Elmore’s protest in March 2025 and ultimately denied the protest, allowing Stein’s name to remain on the ballot. Elmore and the City of Whitehall then sought a writ of prohibition from the Supreme Court of Ohio to prevent the board from placing Stein’s name on the ballot.The Supreme Court of Ohio reviewed the case and determined that the phrase “next preceding” in Section 3(a) of the Whitehall Charter means “immediately preceding.” The court concluded that the two-year residency requirement applies to both ward and at-large candidates for the Whitehall City Council. Since Stein did not meet this requirement, the court held that the board’s denial of Elmore’s protest was unauthorized by law. Consequently, the court granted the writ of prohibition, preventing the board from placing Stein’s name on the November 4, 2025 general-election ballot. View "State ex rel. Elmore v. Franklin County Board of Elections" on Justia Law

Seven petitions were filed with the Lucas County Board of Elections to recall the mayor and six members of the Maumee city council under R.C. 705.92. The board found the petitions valid and certified the recall questions for a special primary election. The City of Maumee and a citizen, Glenn Rambo, protested, arguing that the city’s charter does not provide for recall, R.C. 705.92 does not apply to the city, and the petitions did not comply with the statute. The board denied the protests.The relators sought a writ of prohibition to prevent the board from placing the recall questions on the ballot and a writ of mandamus to order the board to grant their protests. The Supreme Court of Ohio reviewed the case. The court found that Maumee’s charter allows for the removal of elected officials as provided by the Constitution or laws of Ohio, but R.C. 705.92 does not apply to Maumee because it was not adopted under R.C. 705.03. The court held that the board erred in deeming R.C. 705.92 applicable to Maumee.The Supreme Court of Ohio granted the writ of prohibition, preventing the board from placing the recall questions on the ballot, and denied the writ of mandamus as moot. The court concluded that the recall procedure in R.C. 705.92 is not generally applicable to municipalities and can only be adopted as part of a statutory plan of government under R.C. 705.03, which Maumee did not do. View "State ex rel. Maumee v. Lucas County Board of Elections" on Justia Law

An inmate, Thomas Clark, filed a mandamus action against the Ohio Department of Rehabilitation and Correction (DRC) seeking copies of electronic kites he sent to prison staff while incarcerated at the North Central Correctional Complex (NCCC) and the Lebanon Correctional Institution (LCI). He also requested a copy of the chow-hall menu from LCI. Clark claimed that his requests were not fulfilled and sought $2,000 in statutory damages and court costs.The lower court proceedings involved Clark sending public-records requests to LCI staff. The LCI staff forwarded his request for NCCC kites to the appropriate person at NCCC, but Clark did not receive a response. For the chow-hall menu request, LCI staff directed Clark to obtain the menu from his unit manager, which Clark did not do. Clark then filed this mandamus action.The Supreme Court of Ohio reviewed the case and found that Clark was entitled to a writ of mandamus for his request for the NCCC kites because LCI staff had forwarded his request to NCCC, and NCCC did not respond. The court held that DRC must provide Clark with the requested NCCC kites. However, the court denied the writ for the chow-hall menu request, as LCI staff had properly directed Clark to the appropriate person to obtain the menu. The court awarded Clark $1,000 in statutory damages for the NCCC kites request but denied his request for court costs. The court also denied Clark's motion for leave to file rebuttal evidence. View "State ex rel. Clark v. Department of Rehabilitation and Correction" on Justia Law

A couple contracted to buy a lakefront home with the intention of demolishing it and building a new one. They later discovered a publicly recorded sewer line running through the property, which was not listed on the seller's disclosure form. Believing the sewer line would interfere with their construction plans, they attempted to back out of the deal, leading to litigation.The trial court granted summary judgment in favor of the seller, finding that the sewer easement was publicly recorded and that the buyers had constructive notice of its existence. The court also found no evidence that the sewer line materially and adversely impacted the use or value of the property, concluding that it was not a defect requiring disclosure.The Eighth District Court of Appeals reversed the trial court's decision, holding that there was a genuine issue of material fact regarding whether the sewer line materially and adversely affected the buyers' intended use of the property and whether the seller completed the disclosure form in good faith.The Supreme Court of Ohio reversed the appellate court's judgment, reinstating the trial court's decision. The court held that the sewer line did not constitute a material defect that the seller was required to disclose on the Residential Property Disclosure Form. The court reasoned that the term "defect" implies an inadequacy or flaw, and a working sewer line in an inconvenient location does not meet this definition. Additionally, the court noted that the disclosure form requires disclosure of conditions that could inhibit an ordinary buyer's use of the property, not a specific buyer's intended use. Therefore, the seller had no duty to disclose the sewer line, and the buyers' claim of fraudulent concealment failed. View "Ashmus v. Coughlin" on Justia Law

K.W. agreed to buy a MacBook Pro laptop from a seller on the Letgo app, who was later identified as Mamadou Diaw. When K.W. met Diaw to complete the transaction, Diaw and an accomplice stole K.W.'s iPhone and money, assaulted him, and threatened him with a gun. Detective Michael Sturgill subpoenaed Letgo for information about the seller, obtaining an IP address, an email address, and a single location data point.The trial court granted Diaw's motion to suppress the information obtained from Letgo, finding that the police acquired it in violation of the Fourth Amendment. The Tenth District Court of Appeals reversed, holding that Diaw did not have a reasonable expectation of privacy in the location data because it was a single, voluntarily communicated data point that was historical in nature.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District's judgment. The court held that a person generally has no expectation of privacy in information voluntarily shared with third parties. Therefore, the Fourth Amendment does not require law enforcement to obtain a search warrant before securing a single historical location data point from a third-party online-marketplace app. The case was remanded to the trial court for further proceedings consistent with this opinion. View "State v. Diaw" on Justia Law

The case involves Pavan V. Parikh, the Hamilton County clerk of courts, who implemented a policy in May 2022 that eliminated remote online access to court records in residential-eviction cases older than three years from the date of judgment satisfaction. Parikh argued that this policy was to prevent misuse of court documents by the public, such as employers and landlords. The judges of the Hamilton County Municipal Court objected to this policy and issued Administrative Order No. 23-45 in October 2023, directing Parikh to rescind the policy and restore online access to the records. Parikh did not comply, leading to the judges threatening contempt proceedings.Parikh filed a complaint for a writ of prohibition in the First District Court of Appeals to prevent the judges from enforcing the administrative order and holding him in contempt. The judges counterclaimed, requesting a writ of mandamus to compel Parikh to comply with their order. The court of appeals, with visiting judges from the Twelfth District, ruled in favor of the judges, granting their motion for judgment on the pleadings on the prohibition claim and issuing a writ of mandamus ordering Parikh to rescind his policy and comply with the administrative order.The Supreme Court of Ohio reviewed the case and affirmed the court of appeals' judgment. The court held that Parikh had a clear legal duty under R.C. 1901.31(E) to comply with the judges' administrative order. The court also determined that Parikh had an adequate remedy through appeal if held in contempt, and the judges did not patently and unambiguously lack jurisdiction to hold him in contempt for noncompliance. Therefore, the court affirmed the denial of Parikh's request for a writ of prohibition and the granting of the judges' request for a writ of mandamus. View "State ex rel. Parikh v. Berkowitz" on Justia Law