Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court granted a writ of procedendo to compel Franklin County Probate Court Judge Jeffrey Mackey to lift a stay in a probate case and proceed with Relators' adoption petition, holding that the court abused its discretion by allowing the adoption proceeding to languish in this case.In July 2019, Relators filed a petition to adopt Z.W.D., identifying K.T. as the minor child's biological mother. After the Supreme Court held in 2020 that indigent parents have a constitutional right to counsel in adoption proceedings in probate court K.T. asked the probate court magistrate to appoint counsel to represent her because she was indigent. The probate court stayed the matter and then, in October 2021, determined that K.T. was indigent. In April 2022, Relators filed this complaint alleging that the probate court's stay to allow K.T. to apply for indigent representation was unreasonable and unconscionable. The Supreme Court granted a writ and ordered the probate court to appoint counsel for K.T. within thirty days of this decision, holding that the probate court should take all reasonable steps to identify potential counsel. View "State ex rel. T.B. v. Mackey" on Justia Law

The Supreme Court held that 2018 Am.Sub.H.B. 228, which shifted the burden of proof on self-defense to the prosecution, applies to all trials conducted on or after its effective date of March 28, 2019, irrespective of when the underlying alleged criminal conduct occurred.On September 20, 2018, Appellant was indicted for aggravated burglary and other crimes. After a jury trial, Appellant was convicted. On appeal, Appellant argued that she was deprived of a fair trial when the trial court required her to bear the burden of proving that she had acted in self defense. The court of appeals affirmed, holding that the trial court had properly instructed the jury because the burden-shifting changes to Ohio Rev. Code 2901.05 did not apply retroactively. The Supreme Court reversed, holding that H.B. 228 must be applied to all pending and new trials that occur on or after its effective date of March 28, 2019. View "State v. Brooks" 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 claims were not cognizable in habeas corpus.In 1996, Appellant was convicted of aggravated murder and other crimes and sentenced to a life term in prison. In 2021, Appellant filed a petition for a writ of habeas corpus demanding his release from prison on the grounds that the trial court lacked the authority to impose a life term of imprisonment under the circumstances and that certain counts should have been merged for sentencing. The court of appeals dismissed the action, concluding that the petition failed to state a valid claim for relief in habeas corpus. The Supreme Court affirmed, holding that Appellant's claims were not cognizable in habeas corpus. View "Stevens v. Hill" 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 Marion Correctional Institution, holding that there was no error or abuse of discretion.Appellant was convicted of four counts of aggravated murder and sentenced to two consecutive terms of life in prison without the possibility of parole for the murders. Appellant later filed a petition for a writ of habeas corpus alleging errors in the grand jury process that led to his indictment. The court of appeals dismissed the petition. The Supreme Court affirmed and denied Appellant's motion for an order compelling the Mahoning County Clerk of Courts to submit the complete record of his underlying criminal case for consideration on appeal, holding that the court of appeals properly dismissed Appellant's petition for failure to state a claim upon which relief could be granted. View "State ex rel. Barnette v. Hill" on Justia Law

In these two original actions the Supreme Court granted a limited writ of prohibition in each action, holding that the Summit County Court of Common Pleas, General Division, lacked subject-matter jurisdiction to adopt certain paragraphs of its order.Two brothers, who were coexecutors of their deceased father's estate, sought writs of prohibition to prevent the judge of the general division from enforcing her order memorializing a settlement in a judicial-dissolution action, arguing that they were not bound by the order because the general division lacked both subject matter jurisdiction to issue the order and personal jurisdiction over them. The Supreme Court granted a limited writ of prohibition in each action, holding that the general division patently and unambiguously lacked subject-matter jurisdiction to adopt the paragraphs of its order directing the brothers to take actions as coexecutors. View "Neiman v. LaRose" on Justia Law