Justia Ohio Supreme Court Opinion Summaries

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

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