Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court ordered the General Assembly to pass a new congressional-district plan that complied with the Ohio Constitution, holding that the plan adopted by the Ohio Redistricting Commission on March 2, 2022 unduly favored the Republican Party and disfavored the Democratic Party in violation of Ohio Const. art. XIX, 1(C)(3)(a).On January 14, 2022, the Supreme Court held that the congressional-district plan passed by the General Assembly was invalid in its entirety and directed the General Assembly to adopt a new plan that complied with Article XIX. After the redistricting commission adopted the March 2 plan, Petitioners filed original actions challenging the plan. The Supreme Court granted the petition, holding that the March 2 plan did not comply with Article XIX, section 1(C)(3)(a) of the Ohio Constitution and was therefore invalid. View "Santomauro v. McLaughlin" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of prohibition against Geauga County Court of Common Pleas Judge Carolyn J. Paschke, holding that the court of appeals properly dismissed the petition under Civ.R. 12(B)(6).Appellant, a defendant in a divorce case pending before Judge Paschke, brought this petition alleging that Judge Paschke's procedure for issuing orders in his case violated Civ.R. 53 and seeking a writ of prohibition restraining the judge from issuing entires in violation of Civ.R. 53. The court of appeals dismissed the petition for failure to state a valid claim for relief. The Supreme Court affirmed, holding that because the petition was based on an alleged error in Judge Paschke's exercise of jurisdiction and not a lack of subject-matter jurisdiction, prohibition was not an appropriate remedy. View "State ex rel. Jones v. Paschke" on Justia Law

The Supreme Court denied the claims brought by Erik Jones in this expedited election case, holding that Jones was not entitled to a writ of mandamus based on the doctrine of laches.Jones filed a declaration of candidacy and petition to appear on the August 2, 2022 primary ballot as a candidate for the Republican Party State Central Committee, but the Lorain County Board of Elections did not certify his name to the ballot based on the instructions in Ohio Secretary of State Frank LaRose's Directive 2022-34 to reject declarations and petitions filed after February 2, 2022 by state-central-committee-member candidates. Jones subsequently sought a writ of mandamus compelling LaRose to instruct the county boards of elections to accept declarations of candidacy filed before May 4, 2022. The Supreme Court denied the claims, holding that Jones's unreasonable delay in bringing this lawsuit resulted in prejudice to the Board in its administration of the election. View "State ex rel. Jones v. LaRose" on Justia Law

The Supreme Court reversed the judgment of the trial court finding Defendant guilty of kidnapping and rape and a repeat-violent-offender specification and imposing a ten-year sentence on each count, to be served concurrently, holding that the trial court denied Defendant his constitutional right to a fair jury as guaranteed by the Sixth and Fourteenth Amendments to the United States Constitution.At issue was whether Defendant's right to a fair trial was violated when the alleged victim was introduced to the jury as the State's designated representative and was permitted to sit at counsel table with the prosecutor during the proceedings. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court erred in designating the alleged victim as the State's representative and by allowing her to sit at the prosecutor's table and that the error was not harmless, requiring reversal. View "State v. Montgomery" on Justia Law

The Supreme Court denied relief in this original action brought by Relator, an inmate at the Toledo Correctional Institution (TCI), brought seeking a writ of mandamus to fulfill his public records request he previously made to the records custodian for TCI (Respondent), holding that Relator was not entitled to the writ.In her affidavit, Respondent denied that TCI had any records requested by Relator. Respondent then brought this mandamus action. The Supreme Court denied the writ, holding that Relator requested information other than records, and therefore, he was not entitled to a writ or to his requested statutory damages. View "State ex rel. Griffin v. Sehlmeyer" on Justia Law