Justia Ohio Supreme Court Opinion Summaries

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The Supreme Court granted a writ of mandamus ordering Respondent Ohio Secretary of State Frank LaRose to place Relator Tanya Conrath's name on the ballot as the replacement Democratic Party candidate for the state-representative seat in the November 2022 state election, holding that Conrath established that she was entitled to the writ.The Democratic Party candidate for the state-representative seat in the 2022 primary election for state representative of Ohio House District 94 gave notice of his withdrawal from the race after the primary election was held but before the official result of the primary election had been certified. Thereafter, a district committee chose Conrath to be the Democratic party's replacement nominee, and Conrath accepted the nomination. Secretary LaRose, however, concluded that the district committee had lacked authority to select a replacement nominee because Conrath was not a "party candidate." The Supreme Court granted a writ of mandamus, holding that Conrath had a clear legal right to have her name placed on the ballot and that Respondents had a clear legal duty to place Conrath's name on the ballot. View "State ex rel. Conrath v. LaRose" on Justia Law

Posted in: Election Law
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The Supreme Court denied a writ of mandamus sought by Michela Huth compelling the Animal Welfare League of Trumbull County, Inc. (AWL) to inform her how AWL maintains and accesses its records in the ordinary course of business, holding that Huth failed to establish that she was entitled to the writ.Huth sent a AWL, a county humane society, a public-records request for a copy of all criminal complaints filed in any court by agents employed by AWL. After AWL asked Huth to narrow her request, she filed her complaint for a writ of mandamus requiring AWL to inform her how it maintains its records and how those records are accessed in the ordinary course of AWL's operations. The Supreme Court denied the writ and denied her request for damages and attorney fees, holding that AWL was not required to provide AWL the requested information and that Huth was not entitled to statutory damages, court costs, or attorney fees. View "State ex rel. Huth v. Animal Welfare League of Trumbull County, Inc." on Justia Law

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The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court dismissing the indictment in this case with prejudice, holding that the trial court properly dismissed the indictment but erred when it dismissed the indictment with prejudice.At issue was what constitutes adequate notice to inform a wholesale distributor that it is charged with drug trafficking under Ohio's drug-trafficking laws. The State charged Appellants, who were in the business of wholesale distribution, with drug trafficking for acting "not in accordance with Chapter 4729 of the Ohio Revised Code." The trial court granted Appellants' motion to dismiss on the grounds that the State failed to provide them with sufficient notice. The court of appeals reversed. The Supreme Court reversed, holding (1) in a drug-trafficking case against a wholesale distributor, the State must prove that the wholesale distributor failed to act in accordance with Chapter 4729; and (2) the State failed to identify the nature and cause of the accusation against Appellants, and therefore, the case must be dismissed without prejudice. View "State v. Troisi" on Justia Law

Posted in: Criminal Law
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The Supreme Court granted in part writs of mandamus and prohibition against Ronald P. Forsthoefel, a judge on the Ashland County Common Pleas Court, barring Judge Forsthoefel from enforcing his order sealing the documents filed in an underlying dissolution case and ordering him to vacate his sealing order and to conduct a proper review of the documents.The Cincinnati Enquirer requested a writ of mandamus ordering Judge Forsthoefel to vacate his order sealing documents in the dissolution case and to permit public access to the documents and also sought a writ of prohibition barring the judge from enforcing his sealing order. The Supreme Court granted the requested writs in part, holding (1) the Enquirer was entitled to a writ of mandamus ordering Judge Forsthoefel to vacate his sealing order and to conduct a proper review of the documents subject to the sealing order; and (2) the Enquirer was entitled to a writ of prohibition because it had shown entitlement to a writ of mandamus. View "State ex rel. Cincinnati Enquirer v. Forsthoefel" on Justia Law

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The Supreme Court granted a limited writ sought by Relators - Sanduskians for Sandusky and Craig McCloskey II - ordering Respondents - the City of Sandusky and city commission members - to enact an ordinance providing for submission of a proposed charter amendment to Sandusky's electors, holding that Relators were entitled to a limited writ.Relators requested a writ of mandamus ordering Respondents to certify a charter amendment petition for a vote by Sandusky's electors at the November 8, 2022 general election and further sought a writ of mandamus ordering Erie County Board of Elections to place the proposed charter amendment on the November 8, 2022 general election ballot. The Supreme Court granted a limited writ ordering the enactment of an ordinance providing for submission of the proposed amendment at a special election to take place within certain time parameters and conditioned the writ on the Erie County Board of Elections certifying that the charter-amendment petition contained sufficient valid signatures to qualify for submission to the electors, holding that Ohio Rev. Code 731.31 did not apply to Relators' petition to amend Section 25 of the Sandusky Charter. View "State ex rel. Sanduskians for Sandusky v. City of Sandusky" on Justia Law

Posted in: Election Law
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The Supreme Court granted a writ of mandamus ordering the Mahoning County Board of Elections to place Eric Ungaro's name on the November 2022 general election ballot as an independent candidate for the office of state representative, holding that Ungaro successfully established that he was entitled to the writ.Ungaro filed a statement of candidacy and nominating petition to run as an independent candidate for the office of state representative of the 59th Ohio House District in the November 2022 general election. The Board rejected the petition by a vote of three to one. Ungaro then filed this action seeking a writ of mandamus ordering the Board to place his name on the ballot. The Supreme Court affirmed, holding that the Board abused its discretion by invalidating Ungaro's petition in an arbitrary fashion. View "State ex rel. Ungaro v. Mahoning County Bd. of Elections" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's mandamus complaint for failure to satisfy the affidavit requirement of Ohio Rev. Code 2969.25(A), holding that Appellant failed to demonstrate any error in the court of appeals' judgment of dismissal.In 1993, Appellant was convicted of murder. In 2021, Appellant commenced this action seeking a writ of mandamus ordering the Ohio Adult Parole Authority to remove all incorrect information from his file and order a new parole hearing. The court of appeals dismissed the action after finding that Appellant's affidavit of prior actions was fatally deficient. The Supreme Court affirmed, holding that the court of appeals correctly dismissed this action for failure to comply with section 2969.25(A). View "State ex rel. Pointer v. Ohio Adult Parole Authority" on Justia Law

Posted in: Criminal Law
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In this expedited election case the Supreme Court granted a writ of mandamus compelling Ohio Secretary of State Frank La Rose to certify Terpsehore P. Maras's name to the November 8, 2022 ballot as an independent candidate for Ohio Secretary of State, holding that Maras was entitled to the writ.On July 18, 2022, Secretary LaRose informed Maras that she had submitted a significant number of signatures and that her candidacy was certified to the November ballot. Justin Bis subsequently filed a protest against the certification of Maras's candidacy, challenging the validity of sixty-five of the petition signatures. A hearing officer sustained the protest as to eighteen signatures and recommended that Maras be decertified from the ballot. Secretary LaRose adopted most of the hearing officer's conclusions and decertified Maras from the ballot. Maras then filed this original action for a writ of mandamus. The Supreme Court granted relief, holding (1) the Secretary acted in clear disregard of applicable law when he refused to count certain verified signatures; and (2) because with the additional signatures the total number of petition signatures exceeded the threshold required for ballot access, the Secretary is ordered to certify Maras's name to the November 8 ballot as an independent candidate for Ohio Secretary of State. View "State ex rel. Maras v. LaRose" on Justia Law

Posted in: Election Law
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The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus sought by Appellant to compel Judge Julie M. Lynch to vacate certain nunc pro tunc entries, holding that Appellant was not entitled to the writ.Appellant was sentenced in 2003 on more than sixty felony counts involving crimes he committed in four separate cases. This appeal involved three cases that included offenses Appellant committed after postrelease control became part of Ohio's sentencing scheme in 1996. Prior to Appellant's release from prison in 2020, Judge Lynch issued the nunc pro tunc entries at issue, which corrected some of Appellant's sentencing entries to include references to the imposition of a mandatory five-year term of postrelease control. Appellant brought this action seeking a writ of mandamus to compel Judge Lynch to vacate the entries. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant did not have a clear legal right to relief in mandamus. View "State ex rel. Randlett v. Lynch" on Justia Law

Posted in: Criminal Law
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The Supreme Court denied a writ of mandamus ordering Trumbull County Board of Elections and its director and Secretary of State Frank LaRose (collectively, Respondents) to place Sarah Thomas Kovoor's name on the November 8, 2022 general election ballot for the office of judge of the Trumbull County Court of Common Pleas, holding that Relators were not entitled to relief.Relators, the Trumbull County Republican Central Committee and Kovoor, sought a writ of mandamus ordering Respondents to certify Kovoor to the November 2022 general election ballot. Secretary LaRose voted against certifying Kovoor as candidate. The Supreme Court denied the writ of mandamus, holding that Relators did not show a clear legal right to have Kovoor's name placed on the general election ballot as a candidate for the judge of the Trumbull County Court of Common Pleas. View "State ex rel. Trumbull County Republican Central Committee v. Trumbull County Bd. of Elections" on Justia Law