Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court affirmed Defendant's conviction of two counts of aggravated murder and his sentences of death on each count but reversed the trial court's judgment imposing postrelease control on counts three, four, and five, holding that Defendant's convictions and sentences should be affirmed.Specifically, the Supreme Court held (1) the trial court erred in imposing postrelease control for counts that had been merged for sentencing; (2) no other error, individual or cumulative, occurred in the underlying proceedings; and (3) under an independent review of Defendant's death sentences, the evidence supported the findings regarding the aggravated and mitigating circumstances, and the death sentences were proportionate. View "State v. Brinkman" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus to compel Portage County Common Pleas Court Judge Laurie J. Pittman to vacate his convictions for burglary and gross sexual imposition, holding that the court of appeals correctly dismissed Appellant's mandamus complaint.In his mandamus complaint, Appellant argued that he was entitled to relief because the trial court lacked subject-matter jurisdiction to accept his guilty pleas and to sentence him for the offenses for which he was convicted. The court of appeals dismissed the complaint for failure to state a claim. The Supreme Court affirmed, holding that Appellant did not allege a valid claim in mandamus. View "State ex rel. Mitchell v. Pittman" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's complaint seeking a writ of procedendo against the Cuyahoga County Court of Common Pleas, Division of Domestic Relations, holding that Appellant was entitled to a writ of procedendo.M.D., the defendant in a divorce case, commenced this procedendo action in the court of appeals seeking a writ of procedendo compelling the domestic relations court to proceed in the divorce case and a domestic violence civil protection order (DVCPO) case, both of which had been pending since May 31, 2017. The court of appeals dismissed the action. The Supreme Court reversed, holding that the divorce and DVCPO cases far exceeded the time frames stated in the guidelines set by the Rules of Superintendence for the Court of Ohio. View "State ex rel. M.D. v. Kelsey" on Justia Law

The Supreme Court vacated the judgment of the court of appeals affirming the denial by the court of common pleas of Appellants' motion to dismiss concluding that immunity from liability afforded to mental-health providers under Ohio Rev. Code 2305.51 did not apply in this case, holding that the trial court's order denying Appellants' motion to dismiss was not a final, appealable order, and therefore, the court of appeals lacked jurisdiction to issue its judgment.In overruling Appellants' motion to dismiss the trial court concluded that immunity from liability afforded to mental-health providers under section 2305.51 did not apply in this case. The court of appeals affirmed, rejecting Appellants' argument that the trial court erred in holding that Appellants were not entitled to statutory immunity under section 2305.51. The Supreme Court vacated the court of appeals' judgment, holding that the appellate court lacked jurisdiction where the trial court's entry denying Appellants' motion to dismiss was not a final, appealable order. View "Stewart v. Solutions Community Counseling & Recovery Centers, Inc." on Justia Law

In this appeal from a judgment of the Seventh District Court of Appeals, the Supreme Court held that Ohio's Marketable Title Act (MTA), Ohio Rev. Code 5301.47 et seq., applied to an oil and gas interest that had been severed from its surface property.Senterra, Ltd., the owner of the surface property at issue in this case, sought to quiet title to the disputed one-quarter oil and gas interest in its favor, urging the Court to apply the deed-interpretation rule of equity set forth in Duhig v. Peavy-Moore Lumber Co., 144 S.W.2d 878 (Tex. 1940) (the Duhig rule). The heirs to the oil and gas interest argued, in response, that the Duhig rule was inapplicable and that the MTA applied and gave them marketable record title to the interest. The trial court granted summary judgment to Senterra. The Seventh District reversed, ruling that the Duhig rule was inapplicable and that the MTA applied. The Supreme Court affirmed, holding (1) the oil and gas interest retained by the heirs was not subject to the Duhig rule; and (2) the heirs' interest was preserved under the MTA. View "Senterra, Ltd. v. Winland" on Justia Law