Justia Ohio Supreme Court Opinion Summaries

The City of Obetz initiated a mandamus and prohibition action against Franklin County Auditor Michael Stinziano and Franklin County Treasurer Cheryl Brooks Sullivan. The dispute arose from a tax-increment-financing (TIF) arrangement established by Obetz in 1997. Obetz erroneously received TIF proceeds in 2015, 2016, and 2017. To correct this, Obetz returned some funds to the county, but the county also withheld Obetz's real-property-tax distribution for the first half of 2022 and reallocated it to other taxing jurisdictions.The Franklin County Court of Common Pleas initially reviewed the case, where Obetz sought to compel the county to return the funds it had tendered and to pay future settlement distributions without setoff. The lower court's decision led to the current appeal.The Supreme Court of Ohio reviewed the case. The court held that Obetz was not entitled to the return of the $212,963.01 it had voluntarily paid to the county. Additionally, the court denied Obetz's request for the county to pay $194,944.32, which had been withheld and reallocated to other jurisdictions. However, the court granted a limited writ of mandamus, compelling the county to pay future settlement distributions to Obetz without setoff. The court found that the county did not have the authority under R.C. 319.44, R.C. 323.133(B), R.C. 5713.08, or R.C. 5715.22 to withhold future settlement funds from Obetz. The court also denied Obetz's request for a writ of prohibition, as the county's actions did not constitute the exercise of judicial power. View "State ex rel. Obetz v. Stinziano" on Justia Law

Christopher R. Hicks submitted a public-records request to the Union Township, Clermont County Board of Trustees, seeking email- and mail-distribution lists for the township's newsletter. The township denied the request, claiming the lists did not document the township's activities and were not public records. Hicks filed a complaint in the Court of Claims, arguing that the lists were public records documenting the township's functions and activities.The Court of Claims appointed a special master who found that the lists were used for administrative convenience and did not meet the definition of a public record. The Court of Claims adopted this recommendation and denied Hicks's request. Hicks appealed to the Twelfth District Court of Appeals, which affirmed the lower court's decision, agreeing that the lists were used solely for convenience and did not document the township's functions or activities.The Supreme Court of Ohio reviewed the case and reversed the lower court's decision. The court held that the email- and mail-distribution lists are public records under R.C. 149.011(G) because they document the township's functions and activities by showing how the newsletter is distributed to constituents. The court emphasized that the Public Records Act should be construed liberally in favor of broad access and that the lists are central to the township's communication with its constituents. The court ordered that the requested records be made available to Hicks. View "Hicks v. Union Twp. Clermont Cty. Bd. of Trustees" on Justia Law

The case involves a dispute between Ohio Edison Company and the Corder family over the use of herbicides on property subject to easements held by Ohio Edison. The easements, granted in 1948, allow Ohio Edison to maintain electrical transmission lines and to trim, cut, and remove trees, limbs, underbrush, or other obstructions that may interfere with or endanger their infrastructure.Initially, the trial court dismissed the case for lack of jurisdiction, believing it fell under the exclusive jurisdiction of the Public Utilities Commission of Ohio. The Seventh District Court of Appeals reversed this decision, holding that the trial court had jurisdiction and remanded the case to resolve the ambiguity in the easements. The Ohio Supreme Court affirmed the appellate court's jurisdictional ruling but vacated its analysis of the easements, remanding the case to the trial court.On remand, the trial court granted summary judgment to the Corders, holding that the easements did not permit the use of herbicides. The Seventh District Court of Appeals affirmed this decision, finding the easements ambiguous and concluding that they did not authorize the use of herbicides.The Supreme Court of Ohio reviewed the case and determined that the easements unambiguously grant Ohio Edison the right to remove vegetation and other obstructions. The court held that the term "remove" includes the use of herbicides, as the easements do not restrict the methods of removal. Consequently, the Supreme Court reversed the appellate court's judgment and remanded the case to the trial court to issue an entry awarding summary judgment to Ohio Edison. View "Corder v. Ohio Edison Co." on Justia Law

The case involves the termination of a police chief, Erica Barga, by the Village Council of St. Paris. Barga was placed on administrative leave by the mayor, who filed charges against her for insubordination and neglect of duty. Barga requested a public hearing to address these charges. The village council conducted the hearing in public but deliberated in executive session before voting to terminate Barga's employment.The Champaign County Court of Common Pleas upheld the village council's decision, concluding that Barga did not have a substantive or procedural right to have the entire disciplinary hearing open to the public. The court also found that the village council's decision was presumed valid and that Barga had not overcome this presumption.The Second District Court of Appeals affirmed the lower court's decision regarding the Open Meetings Act, relying on a federal district court decision that exempted quasi-judicial proceedings from the Act. However, it found that the common pleas court had applied the wrong standard of review and remanded the case for a de novo review.The Supreme Court of Ohio reversed the court of appeals' decision, holding that the village council violated the Open Meetings Act by deliberating in executive session after Barga requested a public hearing. The court emphasized that the plain terms of the Act required the council to consider the charges in a public hearing. The court remanded the case to the village council for a public hearing in compliance with the Open Meetings Act. View "Barga v. St. Paris Village Council" on Justia Law

Tommy Glover committed a series of armed robberies and kidnappings in May and June 2020, resulting in his convictions for 11 first-degree felonies and six gun specifications. Glover's crimes involved holding victims at gunpoint, forcing them to withdraw money from ATMs, and causing significant emotional trauma. The trial court sentenced Glover to an aggregate term of 60 years in prison, with some sentences running consecutively and others concurrently.The First District Court of Appeals reversed the trial court's sentence, finding it disproportionate to Glover's criminal history, the danger he posed, and the offenses committed. The appellate court modified Glover's sentences to run concurrently, resulting in a reduced aggregate sentence of 25 years. The court of appeals based its decision on the lack of physical harm to the victims and compared Glover's sentence to those in other cases involving both physical and emotional harm.The Supreme Court of Ohio reviewed the case and found that the appellate court erred in its analysis. The Supreme Court emphasized that the appellate-review statute limits the appellate court's review to whether the trial court's findings under R.C. 2929.14(C)(4) are clearly and convincingly unsupported by the record. The Supreme Court concluded that the trial court's findings were supported by substantial evidence, including the severe emotional harm inflicted on the victims and Glover's lack of remorse. The Supreme Court reversed the appellate court's judgment and reinstated the trial court's original sentence of 60 years. View "State v. Glover" on Justia Law

The case involves a group of relators seeking to place a proposed constitutional amendment titled "Ohio Voters Bill of Rights" before Ohio voters. The relators submitted the text and a summary of their proposed amendment to the Ohio Attorney General, Dave Yost, for certification. The Attorney General refused to certify the summary, arguing that the title "Ohio Voters Bill of Rights" was not a fair and truthful statement of the proposed amendment.Previously, the relators had submitted their petition with a different title, "Secure and Fair Elections," which the Attorney General also rejected for similar reasons. The relators revised their petition and resubmitted it with the new title, but the Attorney General again refused to certify it, focusing solely on the title's perceived inaccuracy.The Supreme Court of Ohio reviewed the case. The court determined that the Attorney General's authority under R.C. 3519.01(A) is limited to examining the summary of a proposed constitutional amendment, not its title. The court found that the Attorney General exceeded his statutory authority by rejecting the petition based on the title. The court noted that the statutory scheme differentiates between a "summary" and a "title," and the Attorney General's duty is to review only the summary.The Supreme Court of Ohio granted a limited writ of mandamus, ordering the Attorney General to examine the summary of the relators' proposed amendment within ten days, determine whether it is a fair and truthful statement, and, if so, certify and forward the petition to the Ohio Ballot Board. The court emphasized that the Attorney General must perform his statutory duty without considering the title of the proposed amendment. View "State ex rel. Dudley v. Yost" on Justia Law

Two men opened fire at a party, killing one person and wounding eight others. James Echols was identified as one of the shooters. While in jail awaiting trial, Echols allegedly threatened the State’s principal witness and wrote a letter suggesting harm to the witness’s wife. The trial court admitted evidence of these acts at Echols’s trial, along with other evidence of his participation in the crime. Echols was convicted.The First District Court of Appeals affirmed Echols’s conviction, finding that the witness-intimidation evidence was properly admitted to show Echols’s consciousness of guilt. Echols argued that the trial court should have analyzed the evidence as “other acts” evidence under Evid.R. 404(B) and followed the analytical framework outlined in State v. Hartman. The appellate court did not explicitly perform an Evid.R. 404(B) analysis but concluded that the evidence was admissible.The Supreme Court of Ohio reviewed the case and agreed that the witness-intimidation evidence constituted other-acts evidence under Evid.R. 404(B). The court found no error in the admission of this evidence, as it was relevant for a nonpropensity purpose—showing Echols’s consciousness of guilt. The court also determined that the probative value of the evidence was not substantially outweighed by the danger of unfair prejudice, confusion of issues, or misleading the jury. The court affirmed the judgment of the First District Court of Appeals. View "State v. Echols" on Justia Law

A man named Alonzo Kyles was indicted for animal cruelty after police found a cat soaked in bleach in an apartment building's basement stairwell. Kyles admitted to pouring bleach to scare the cat away because he was afraid of cats. The cat had red and swollen paws, no collar, and was unclaimed by anyone in the building. The cat was taken to an animal hospital where a veterinarian treated it for ulcerations, a common symptom of bleach exposure. Kyles was found guilty of animal cruelty and sentenced to nine months in jail.The Eighth District Court of Appeals reviewed the case and reversed Kyles's conviction. The court held that the statute under which Kyles was convicted, R.C. 959.131(C), required the State to prove that the cat was a "companion animal." The court interpreted the statute to mean that only dogs and cats that are "kept" qualify as companion animals. Since the State did not provide sufficient evidence that the cat was "kept," the court found the conviction unsupported by sufficient evidence.The Supreme Court of Ohio reviewed the case and reversed the Eighth District's decision. The court held that R.C. 959.131(C) protects all dogs and cats, not just those that are "kept." The court emphasized that the statute's language includes "any dog or cat regardless of where it is kept," meaning the protection extends to all dogs and cats without regard to their living situation. The case was remanded to the Eighth District Court of Appeals to consider Kyles's remaining arguments. View "State v. Kyles" on Justia Law

A juvenile court judge in Hamilton County, Ohio, presided over the trial of a thirteen-year-old accused of felonious assault. The judge found the juvenile not delinquent and sealed the case record under Ohio Revised Code (R.C.) 2151.356(B)(1)(d). After the juvenile was later killed, the Cincinnati Enquirer requested the trial transcript, which the judge denied, citing the statute.The Cincinnati Enquirer challenged the constitutionality of R.C. 2151.356, arguing that the Ohio Constitution's open courts provision prohibits sealing court records without an individualized determination balancing the interests of the juvenile and the public. The juvenile court judge argued that the open courts provision does not apply to juvenile delinquency proceedings, relying on precedent from the Ohio Supreme Court.The Supreme Court of Ohio reviewed the case and held that the open courts provision of the Ohio Constitution applies to juvenile delinquency proceedings. The court determined that R.C. 2151.356 is unconstitutional because it mandates the sealing of records without an individualized balancing of interests. The court granted a writ of mandamus ordering the juvenile court judge to provide access to the trial transcript and a writ of prohibition preventing the enforcement of the sealing order. View "State ex rel. Cincinnati Enquirer v. Bloom" on Justia Law

A property developer settled claims with the U.S. Department of Justice for alleged violations of the Fair Housing Act (FHA) and sought to assert a state-law claim for contribution against other companies involved in developing the properties. The developer, Epcon Communities Franchising, L.L.C., alleged that the franchisees, including Wilcox Development Group, L.L.C., failed to comply with the FHA in their construction and design of certain properties.The trial court dismissed the case, not on the grounds argued by Wilcox, but on the theory that if a state-law cause of action for contribution existed, it was preempted by federal law. The Tenth District Court of Appeals affirmed this decision, and Epcon appealed the preemption issue to the Supreme Court of Ohio.The Supreme Court of Ohio reviewed the case and determined that the trial court erred in deciding the case on the basis of federal preemption. The court emphasized principles of judicial restraint, noting that no party had argued for federal preemption and that courts should avoid deciding constitutional questions unless necessary. The court also highlighted that the preemption issue was hypothetical and should not have been addressed without first determining whether a state-law contribution claim was available.The Supreme Court of Ohio reversed the judgments of the lower courts and remanded the case to the trial court to consider whether the facts alleged present a claim for relief under Ohio law. The court did not address the preemption issue, as it was not properly presented by the parties and was unnecessary to resolve at this stage. View "Epcon Communities Franchising, L.L.C. v. Wilcox Dev. Group, L.L.C." on Justia Law