Justia Ohio Supreme Court Opinion Summaries

The Supreme Court held that the delayed opening of an amusement park owned by Defendant caused by the government-mandated shutdown imposed by the state in response to the COVID-19 pandemic did not, by itself, establish a claim by a season-pass holder that Defendant breached the terms and conditions of the season pass it issued for the 2020 season.Plaintiff, a season-pass holder, brought this action asserting breach of contract and unjust enrichment for Defendant's failure to open its amusement parks in May and June 2020. The trial court dismissed the complaint with prejudice. The court of appeals reversed, finding that the parties were subject to the terms and conditions of the pass and that Defendant could not revoke the season pass without compensating Plaintiff. The Supreme Court reversed, holding (1) according to the terms and conditions tissue, Defendant could change its dates of operation without advance notice and close attractions for the government-mandated shutdown; and (2) therefore, Plaintiff's breach of contract action failed as a matter of law, and there was no unjust enrichment. View "Valentine v. Cedar Fair, L.P." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals in this matter involving the 1882 transfer of property known today as Wade Park located in the city of Cleveland, holding that the Marketable Title Act (MTA), Ohio Rev. Code 5301.47 et seq., did not extinguish the reverter rights of Appellants and cross-Appellees (collectively, the Heirs).At issue was the interpretation and application of park-use restrictions in the deed donating the subject property to the city. The trial court interpreted the deed to both restrict the park's use and to promote its development, thus finding that Cleveland Botanical Garden (CBG), the City, and University Circle, Inc. did not violate the park-use restrictions. The court further found that the MTA extinguished the Heirs' reverter rights. The court of appeals affirmed the trial court's finding that CBG's operation in the park did not violate the deed's park-use restrictions but reversed the judgment regarding application of the MTA. The Supreme Court affirmed, holding (1) there was no violation of the deed's park-use restrictions; and (2) the MTA may not be used to extinguish the Heirs' interests. View "Cleveland Botanical Garden v. Worthington Drewien" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against the warden of the Lake Erie Correctional Institution, holding that the court of appeals correctly dismissed the petition.Appellant, who was serving an aggregate prison term of up to fifty-six years for criminal convictions dating back to 1976, filed a petition for a writ of habeas corpus in 2021, arguing that his prison term expired in 2011 and that he was entitled to immediate release. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that where Appellant had been transferred to the Mansfield Correctional Institution in Richland County, the court of appeals correctly dismissed the petition for failure to state a claim. View "State ex rel. Robinson v. Fender" on Justia Law

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