Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's action seeking a writ of mandamus ordering the trial court to hold a new sentencing hearing, holding that the court of appeals correctly dismissed the mandamus petition.Appellant was convicted of child endangering and felony murder. The trial court merged the offenses and determined that the sentences should run concurrently. Appellant later moved to vacate the "void sentences." The court of appeals concluded that the judgment of conviction was void because only one sentence could be imposed for the merged offenses. On remand, the trial court modified the sentence. Appellant subsequently brought this mandamus action asking the court of appeals to order the trial court to vacate its previous judgment and hold a new sentencing hearing. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant's appeal of the modified sentencing order constituted an adequate remedy in the ordinary course of law. View "State ex rel. Cherry v. Bryant" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus against the current prison warden for failing to state a claim upon which relief could be granted, holding that there was no error.Appellant pleaded guilty to several crimes, including two counts of gross sexual imposition and one count of rape. Appellant later filed a petition for a writ of habeas corpus, claiming that the trial court lacked jurisdiction to accept his plea and sentence him because his competency had been called into question. The court of appeals granted the warden's motion to dismiss. The Supreme Court affirmed, holding that habeas corpus will not lie in this case. View "Rance v. Watson" on Justia Law

The Supreme Court granted in part and denied in part a writ of mandamus ordering the Ohio Department of Rehabilitation and Correction (DRC) to provide certain records that Relator requested under the Public Records Act, Ohio Rev. Code 149.43, holding that Relator was entitled to a writ of mandamus compelling DRC to produce inmate master file documents.After Relator's request for documents was denied he commenced this action seeking a writ of mandamus compelling DRC to provide a copy of his inmate master file and all kites, grievances and appeals filed by him through the electronic-kite system. The Supreme Court granted the writ in part, holding (1) Relator failed to show a clear legal right to a writ of mandamus to compel the produce of the grievance-related records; (2) the DRC must produce the requested records; and (3) Relator was entitled to an award of the statutory maximum of $1,000 in damages. View "State ex rel. Mobley v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and/or procedendo against Franklin County Common Please Court Judge Carl A. Aveni II, holding that mandamus nor procendendo did not lie where Appellant had an adequate remedy in the ordinary course of the law.Appellant was found guilty of felony murder and felonious assault and sentenced to an aggregate prison term of twenty-five years to life. Appellant later filed the underlying complaint alleging that he was entitled to a new sentencing entry because the sentencing entry did not identify the felony underlying his felony-murder conviction. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law that he could have pursued in the ordinary course of the law. View "State ex rel. White v. Aveni" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that Appellant was not entitled to relief on his allegations of error.Appellant was an adult when a complaint was filed charging him with delinquency in connection with a shooting death that occurred when Appellant was a minor. The juvenile court transferred Appellant to the adult court, where he was convicted of aggravated murder and other crimes. Appellant later filed a petition for a writ of habeas corpus, which the court of appeals dismissed. The Supreme Court affirmed, holding (1) Appellant failed to allege a jurisdictional defect in the juvenile court's transfer of his criminal case to the adult court; and (2) Petitioner had an adequate remedy in the ordinary course of law. View "State ex rel. Parker v. Black" on Justia Law