Justia Ohio Supreme Court Opinion Summaries

The Supreme Court vacated Defendant's conviction for aggravated burglary, vacated the finding of guilt on count three charging Defendant with felony murder during an aggravated battery, and dismissed the death penalty specifications predicated on aggravated burglary but affirmed Defendant's remaining convictions and his death sentence, holding that there was insufficient evidence to convict Defendant of burglary.After a trial, a jury found Defendant guilty of aggravated murder and three accompanying death-penalty specifications. The trial court sentenced Defendant to death. The Supreme Court largely affirmed, holding (1) contrary to Defendant's argument on appeal, the indictment in this case was not defective; (2) there was insufficient evidence to convict Defendant of aggravated burglary; (3) no plain error occurred during the prosecutor's trial-phase closing argument; and (4) there were constitutional violations in this case. View "State v. Whitaker" on Justia Law

The Supreme Court dismissed this original action seeking a writ of mandamus against Geauga County ordering the county to proceed under Ohio Rev. Code 305.14 with the submission and approval of Judge Timothy Grendell's application for appointment of counsel, holding that the case was moot.Judge Grendell, judge of the Geauga County Court of Common Pleas, brought this action seeking a writ of mandamus and also filed a motion for a peremptory writ of mandamus and a motion to strike the County's notice of mootness. The Supreme Court denied the motion to strike as futile, dismissed the case, and denied Judge Grendell's motion for a peremptory writ, holding that the case was moot. View "State ex rel. Grendell v. Geauga County Board of Commissioners" on Justia Law

The Supreme Court held that Ohio's antiblocking statute, Ohio Rev. Code 5589.21, which prohibits a stopped train from blocking a railroad crossing for more than five minutes, is preempted by the Interstate Commerce Commission Termination Act, 49 U.S.C. 10101 et seq., and that the Federal Railroad Safety Act, 49 U.S.C. 20101 et seq., does not exempt section 5589.21 from the Termination Act's preemptive force.The State charged CSX Transportation, Inc. with violating section 5589.21 on five occasions. The trial court dismissed the charges, concluding that the Termination Act and the Safety Act preempted section 5589.21. The court of appeals reversed, holding that federal law did not preempt the antiblocking statute. The Supreme Court reversed and reinstated the trial court's dismissal of the charges brought against CSX, holding that section 5589.21 is preempted by federal law and therefore may not be enforced against CSX. View "State v. CSX Transportation, Inc." 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 Warden Ed Sheldon of the Allen-Oakwood Correctional Institution, holding that the court of appeals properly dismissed the petition.Appellant, an inmate, filed a petition for a writ of habeas corpus alleging that he had served his entire prison sentence. The court of appeals dismissed the habeas corpus petition for failure to comply with Ohio Rev. Code 2725.04(D), which requires a habeas petition to contain a copy of the commitment or cause of detention. The Supreme Court affirmed, holding that where Appellant failed to attach all sentencing records to his habeas corpus petition, the court of appeals properly dismissed the petition. View "State ex rel. Davis v. Sheldon" on Justia Law

The Supreme Court held that a trial court lacks discretion to deny a request for a recommended change in the commitment conditions of a mentally ill person subject to court-ordered commitment to a mental health facility when the state has failed to present clear and convincing evidence that the change represents a threat to public safety or any person.Appellant was found not guilty by reason of insanity of murder, tampering with evidence, and abuse of a corpse. The trial court ordered Appellant committed to a mental health facility. The chief clinical officer at the facility later filed a request with the trial court asking that Appellant be allowed to leave the facility to go on trips (Level IV community movement). The trial court denied the request, and the appellate court affirmed. The Supreme Court reversed, holding that the appellate court erred in concluding that the trial court had discretion to deny the requested change in Appellant's commitment level even if the state failed to meet its burden of proof. View "State v. Stutler" on Justia Law

The Supreme Court denied the writ of mandamus sought by Brian Ames, a candidate for the Republican Party State Central Committee for Senate District 28 in the August 2022 primary election, holding that Ames was not entitled to the writ.Ames brought this expedited election matter asking for a writ of mandamus requiring Secretary of State Frank LaRose to direct three count boards of elections to "challenge" electors who requested a ballot for a party other than the other for which the elector voted in the May 2022 primary election. Ames further requested that ballots cast in the August primary be "segregated according to the party for which the elector voted in May" and that ballots cast for a different party not be counted. The Supreme Court denied the writ, holding (1) the writ was moot as to Secretary LaRose; and (2) as to the boards of elections, the writ is denied because Ames was not entitled to the relief he sought. View "State ex rel. Ames v. LaRose" on Justia Law

The Supreme Court vacated the judgment of the court of appeals determining that Appellant's appeal of the denial of his motion to modify the terms of his intervention-in-lieu-of-conviction (ILC) supervision was moot and declining to address the merits, holding that the court erred.Appellant was charged with aggravated possession of drugs and requested ILC under Ohio Rev. Code 2951.041. The trial court granted the request. Appellant later moved to modify the terms of his ILC supervision. The trial court denied the motion. The court of appeals dismissed the appeal as moot. The Supreme Court vacated the judgment below, holding that the order denying the modification of the conditions of ILC was not a final appealable order. View "State v. Yontz" on Justia Law

The Supreme Court affirmed the decision of the Ohio Power Siting Board to approve the application of Icebreaker Windpower, Inc. for a certificate of environmental compatibility and public need to build a six-turbine wind-powered electric-generation facility in Lake Erie, holding that Appellants did not meet their burden of demonstrating that the Board's decision was against the manifest weight of the evidence.Specifically, the Supreme Court held (1) there was sufficient evidence in the record before the Board for it to determine the nature of the probable environmental impact of the project under Ohio Rev. Code 4906.10(A)(2) and whether the project represented the minimum adverse environmental impact under Ohio Rev. Code 4906.10(A)(3); and (2) the Board did not err in determining that it lacked jurisdiction to consider the residents' public-trust argument. View "In re Application of Icebreaker Windpower, Inc." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's decision to overrule Defendant's motion for leave to move for a new trial, holding that the trial court abused its discretion in denying Defendant's motion for leave to move for a new trial.After a jury trial, Defendant was found guilty of rape and sentenced to eleven years in prison. The court of appeals affirmed. Defendant subsequently filed a motion for leave to move for a new trial, asserting that certain undisclosed evidence was exculpatory. The trial court overruled the motion. The court of appeals affirmed, concluding that Defendant's motion for leave was untimely. The Supreme Court reversed, holding that Defendant's motion for leave to move for a new trial should be granted because he was unavoidably prevented from timely moving for a new trial within the time specified in Crim.R. 33(B) due to the state's suppression of evidence. View "State v. McNeal" on Justia Law

The Supreme Court denied a petition for a writ of habeas corpus against Respondent, warden at the Grafton Correctional Institution (GCI), sought by Petitioner, an inmate at GCI, holding that Petitioner was not entitled to the writ.Petitioner pleaded guilty to one count of gross sexual imposition and was sentenced to a prison term of two to five years and placed on probation. He later pled guilty to rape and felonious assault. Eight years later, Petitioner pleaded guilty to attempted rape. In his petition, Petitioner alleged that he had served his maximum prison sentence. The Supreme Court denied relief, holding that Petitioner's sentence will not expire until at least 2026, and therefore, Petitioner was not entitled to a writ of habeas corpus. View "Jones v. Foley" on Justia Law