Justia Ohio Supreme Court Opinion Summaries

The Supreme Court denied a writ of mandamus sought by Relator, a prison inmate, in this original action seeking to compel the warden of the Mansfield Correctional Institution to provide copies of electronic kites between Relator and a prison staff member, holding that the mandamus claim was moot.Relator submitted a request that the warden produce the subject kites under Ohio's Public Records Act, Ohio Rev. Code 149.43. When Relator did not immediately receive the requested documents he filed his writ of mandamus. Thereafter, the warden submitted all records responsive to Relator's request. The Supreme Court denied the writ of mandamus as moot but awarded statutory damages in the amount of $900, holding that because the warden did not timely comply with his obligations Relator was entitled to $900 in statutory damages. View "State ex rel. Suggs v. McConahay" on Justia Law

The Supreme Court determined that a warrantless search conducted in this case did not comport with the Fourth Amendment under the "single-purpose-container exception" to the warrant requirement, holding that when police search a bookbag in a home under circumstances that do not give rise to any exigency they must first obtain a warrant.After he was charged with illegal possession of drugs Defendant filed a motion to suppress, arguing that the warrantless search of the book bag conducted by a law enforcement officer was unlawful. The trial court denied the motion, concluding that the warrantless search was lawful because the book bag was in plain view and the officer had probable cause to suspect it contained contraband. The court of appeals affirmed. The Supreme Court reversed, holding (1) absent exigent circumstances, the search of a closed container requires a warrant; and (2) the single-purpose-container exception to the warrant did not apply in this case because a bookbag is not a single-purpose drug container. View "State v. Burroughs" on Justia Law

The Supreme Court granted a writ of mandamus requested by six relators (the original relators) in this expedited election case and ordered the county boards of elections to accept the declarations and petitions and to certify the candidates to the ballot if they satisfy the other requirements for ballot access, holding that the original relators were entitled to the writ.The original relators filed declarations of candidacy in May 2022 to appear on the August 2, 2022 ballot as a candidate for a partisan nomination, as a candidate for a political-party central committee, or as a write-in candidate. Two intervening relators filed declarations of candidacy and petitions in June 20222 to run for partisan nominations. Secretary of State Frank Rose instructed the county boards of elections to reject candidate declarations filed after February. The Supreme Court granted a writ of mandamus requested by the original relators seeking to compel LaRose to instruct the boards to accept their declarations of candidacy and denied the intervening relators' request for a writ of mandamus, holding that the original relators were entitled to mandamus relief. View "State ex rel. DeMora v. LaRose" on Justia Law

The Supreme Court granted in part and denied in part a writ of mandamus compelling the Ohio Department of Rehabilitation and Correction (DRC) to produce records requested under Ohio's Public Records Act, Ohio Rev. Code 149.43, holding that Relator was entitled to mandamus relief as to certain requests.In addition to his mandamus request, Relator sought an award of statutory damages and leave to amend his mandamus complaint to include additional respondents. The Supreme Court granted the writ in part, holding (1) DRC withheld some of the requested records based on a public records exception that was inapplicable in this case; (2) this Court denies Relator's request for leave to add certain entities as respondents; and (3) Relator was not eligible to receive statutory damages. View "State ex rel. Reese v. Ohio Dep't of Rehabilitation & Correction Legal Dep't" on Justia Law

The Supreme Court denied a writ of prohibition sought by LG Chem, Ltd., a defendant in a products-liability action pending before Judge Michael Goulding in the Lucas County Court of Common Pleas, holding that LG Chem did not demonstrate a patent and unambiguous lack of personal jurisdiction in the trial court.LG Chem filed a motion to dismiss the underlying products-liability action for lack of personal jurisdiction, which Judge Goulding denied without a hearing. Thereafter, LG Chem filed this action seeking a writ of prohibition preventing Judge Goulding from exercising jurisdiction over the action. The Supreme Court denied the requested writ of prohibition, holding that LG Chem failed to show that there was a patent and unambiguous lack of personal jurisdiction over it in the trial court. View "LG Chem, Ltd. v. Goulding" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus ordering the Industrial Commission of Ohio to vacate its decision granting a specific safety requirement (VSSR) award to Josue Morales, holding that Target Auto Repair failed to establish plain error in the proceedings below.Morales sustained injuries while working as a technician for Target Auto Repair. His workers' compensation claim was allowed for multiple conditions. The Commission further granted Morales's application for a VSSR award in the amount of fifty percent of the maximum weekly rate. Target Auto Repair subsequently brought this mandamus action. The court of appeals denied the mandamus request. The Supreme Court affirmed, holding that Target Auto Repair may not appeal the court of appeals' adoption of findings of fact or conclusions of law to which it failed timely to object. View "State ex rel. Target Auto Repair v. Morales" on Justia Law

In consolidated actions, the Supreme Court of Ohio held that an offense-and-incident report, which initiates a police investigation and is a public record under Ohio’s Public Records Act, R.C. 149.43, is not limited to the form that police officers fill out in order to report the incident but also includes certain contemporaneous reports created by the investigating officers that document the officers’ observations and the statements of witnesses at the scene. The court ordered Chillicothe to disclose a limited number “supplement narratives” that the city had withheld when Myers had requested the public-record incident reports. The court concluded that other supplement narratives constitute confidential law-enforcement investigatory records, “investigatory work product,” under R.C. 149.43(A)(2)(c). The most important factor is timing; the initial observations by officers and the initial witness statements taken at the physical location close to the time that the incident occurred constitute incident information that may not be regarded as specific investigatory work product, even when the information has not been incorporated into the incident-report form. View "Myers v. Meyers" on Justia Law

The Supreme Court dismissed this original action in which Relators sought a writ of mandamus against the Ohio State Senate and its thirty-three members individually, holding that this Court lacked jurisdiction to grant the relief sought.Relators sought a writ of mandamus to compel the House respondents to uphold Ohio Const. art. I, 21. The Supreme Court concluded that the request could be read either as a request to compel the House respondents to enact legislation prohibiting the practices to which Relators objected or as a request to prohibit the respondents from enacting legislation that would conflict with Article I, Section 21. The Supreme Court dismissed this action, holding that, under either theory, the relief sought was beyond the Court's jurisdiction to grant. View "State ex rel. Johnson v. Ohio State Senate" on Justia Law

The Supreme Court dismissed this original action in which Relators sought a writ of mandamus against the Ohio House of Representatives and ninety-eight of members individually, holding that this Court lacked jurisdiction over the complaint.Relators sought a writ of mandamus to compel the House respondents to uphold Ohio Const. art. I, 21. The Supreme Court concluded that the request could be read either as a request to compel the House respondents to enact legislation prohibiting the practices to which Relators objected or as a request to prohibit the respondents from enacting legislation that would conflict with Article I, Section 21. The Supreme Court dismissed this action, holding that, under either theory, the relief sought was beyond the Court's jurisdiction to grant. View "State ex rel. Jones v. Ohio House of Representatives" on Justia Law

The Supreme Court reversed the judgment of the court of appeals upholding Defendant's sentence, holding that a defendant's display of disrespect toward a trial court is not a permissible sentencing factor that the court may consider under Ohio Rev. Code 2929.11 and 2929.12.The trial court in this case increased Defendant's prison sentence by six years in response to Defendant's misbehavior while reacting to the length of a previously-imposed prison sentence. The court of appeals affirmed. The Supreme Court reversed, holding (1) a defendant's outburst or other courtroom misbehavior may not result in an increased sentence for the underlying crime; and (2) the six-year increase in Defendant's sentence was contrary to law. View "State v. Bryant" on Justia Law