Justia Ohio Supreme Court Opinion Summaries

The Supreme Court held that the General Assembly-district plan (the plan) adopted by the Ohio Redistricting Commission in September 2021 to be effective for the next four years was invalid under Ohio Const. art. XI, 6(A) and 6(B).The complaints in these three cases alleged that the plan was invalid because the Commission did not attempt to draw it to meet the standards of partisan fairness and proportionality. The Supreme Court agreed, holding that the plan was invalid because the Commission did not attempt to draw it to meet the proportionality standard in article XI, section 6(B) and did not attempt to draw it to met the standard in section 6(A) that no plan shall be drawn primarily to favor a political party. View "League of Women Voters of Ohio v. Ohio Redistricting Committee" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting a writ of habeas corpus ordering the reduction of Petitioner's bail from $1,500,000 to $500,000, holding that the court of appeals did not err.Petitioner was indicted on two counts of murder, one count of aggravated robbery, and one count of aggravated burglary. The district court set bail of $750,000 on the murder charge and a separate bail of $750,000 on the aggravated robbery charge. Petitioner filed two motions for bail reduction, which the trial court denied. Petitioner then filed a petition for a writ of habeas corpus. The court of appeals granted the writ, concluding that Petitioner's bail amount was excessive and reducing his bail to $500,000. The Supreme Court affirmed, holding that the trial court's financial condition of bail was excessive and that the record supported the court of appeals' decision to reduce Petitioner's bail. View "DuBose v. McGuffey" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against the Portage County Board of Revision for lack of standing, holding that the court of appeals properly dismissed the complaint for lack of standing.Appellant brought his complaint asking the court to issue a writ of mandamus compelling the Portage County Board of Revision to create hearing boards, to record the name of the board member assigned to each board, and to revoke any and all designations of alternates made by the board. The court of appeals granted the board's motion to dismiss. The Supreme Court affirmed, holding that Appellant lacked standing to bring this mandamus action. View "State ex rel. Ames v. Portage County Board of Revision" on Justia Law

The Supreme Court reversed the judgment of the court of appeals denying Appellant's motion for an award of statutory damages under the Ohio Public Records Act, Ohio Rev. Code 149.43, holding that Appellant was entitled to statutory damages.Appellant, an inmate, sent a request to the Cleveland Police Forensic Laboratory (CPFL) for three categories of public records. When CPFL did not respond to his request, Appellant filed a mandamus action and sought statutory damages under section 149.43(C)(2). The court of appeals granted a writ of mandamus compelling the production of some of the requested records and denied Appellant's request for statutory damages. The Supreme Court reversed and granted Appellant's application for an award of statutory damages, holding that, given the length of time during which the CPFL failed to respond, Appellant was entitled to the maximum amount permitted under the statute. View "State ex rel. Ellis v. Cleveland Police Forensic Laboratory" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the trial court granting Defendant's motion to suppress in this criminal case, holding that the absence of a signature on an arrest warrant itself alone does not negate the warrant's validity.The warrant to arrest Defendant in this case was not signed by an authorized court officer. On appeal, Defendant argued that the unsigned arrest warrant did not comply with Crim.R. 4 and was therefore invalid. The Supreme Court held (1) the arrest warrant at issue adequately complied with the requirements of Crim.R. 4 despite the absence of a court official's signature on the warrant; and (2) Defendant's arrest pursuant to the warrant did not violate the Fourth Amendment. View "State v. Harrison" on Justia Law

The Supreme Court affirmed the judgment of the court of appeal concluding that a municipality does not violate Ohio Const. art. XVIII, 6 by selling a surplus of electricity to customers outside the municipality's boundaries, holding that the court of appeals did not err.The City of Cleveland sold outside its boundaries approximately four percent of the electricity it sold inside its boundaries. Cleveland Electric Illuminating Company (CEI) brought this complaint arguing that the electricity the City sold extraterritorially as surplus violated this Court's decision in Toledo Edison Co. v. Bryan, 737 N.E.2d 529 (2000) and the Ohio Constitution. The trial court granted summary judgment for the City. The court of appeals reversed, determining (1) Article XVIII, Section 6 does not require a municipality to buy the precise amount of electricity required by its inhabitants at any given time, and (2) questions of material fact existed as to whether the City obtained surplus electricity for the sole purpose of selling it to a neighboring city. The Supreme Court affirmed, holding that while a municipality may not acquire excess capacity for the sole purpose of reselling it outside the municipality's territorial boundaries, the municipality is not required to purchase the exact amount of electricity necessary to satisfy the current needs of its territorial customers. View "Cleveland Electric Illuminating Co. v. Cleveland" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition against Appellees - Judge Dale A. Crawford and the Hocking County Common Pleas Court - but affirmed the denial of her motion for disqualification of attorney Randall L. Lambert, holding that the court of appeals erred in part.Appellant was found guilty of assaulting a police officer. At a sentencing hearing at which Appellant appeared without counsel, Appellant refused to sign a waiver-of-counsel form. Judge Crawford conducted the sentencing hearing, at the end of which he imposed a six-month sentence in the county jail and ordered Defendant to pay a fine, restitution, and court costs. Appellant filed a complaint for writs of mandamus and prohibition alleging that Judge Crawford lacked jurisdiction to hold the sentencing hearing because she had not waived her right to counsel. The court of appeals dismissed the complaint and denied the motion to disqualify Lambert. The Supreme Court reversed in part, holding that Appellant stated a colorable claim that Judge Crawford violated her Sixth Amendment rights when he ordered her to not communicate with any lawyer and then sentenced her and that this error rendered the sentencing entry void. View "State ex rel. Ogle v. Hocking County Common Pleas Court" on Justia Law

The Supreme Court granted the motion to dismiss this complaint brought by Relator, Ohio Stands Up!, Inc., seeking writs of prohibition and mandamus against Respondents, the Ohio Governor and the Director of the Office of Budget and Management, holding that Relator lacked standing to bring this original action.In its prayer for relief, Relator argued that the lottery entailing the expenditure of over $5 million to encourage Ohio residents to receive COVID-19 vaccinations was unconstitutional and discriminatory and sought to prevent Respondents from both spending the money on the lottery and from injecting the vaccines into Ohio's children. Respondents filed a motion to dismiss, arguing that Relator lacked standing. The Supreme Court agreed and granted the motion, holding that Relator failed to establish that it had standing to seeking a writ of prohibition or writ of mandamus in this original action. View "State ex rel. Ohio Stands Up!, Inc. v. DeWine" on Justia Law

The Supreme Court denied as moot Alexander Maxwell's request for a writ of prohibition to prevent the village of Brice from adjudicating an alleged traffic violation through an administrative hearing, holding that the prohibition claim was moot.In support of the village's contention that this case was moot, the village's mayor attested that the village was no longer holding administrative hearings. After the village filed its merit brief, Maxwell moved to strike portions of the brief and the village's evidence. The Supreme Court denied Maxwell's motion to strike, granted his motion for leave to submit supplemental evidence, and denied the writ of prohibition as moot, holding that the evidence supported the mayor's testimony that the village had ceased conducting administrative hearings on traffic citation and that this prohibition action was moot. View "State ex rel. Maxwell v. Brice" on Justia Law

The Supreme Court declined in this case to recognize an exception to the general rule that an adjacent landowner generally owes no duty of care to a motorist who leaves the regularly traveled portion of the road and strikes a stationary object in the right-of-way, holding that Defendants in this case did not owe a duty of care to a motorist with respect to their mailbox.Plaintiff sustained catastrophic injuries as a result of his collision with Defendants' reinforced mailbox after hitting a patch of ice and leaving the ordinarily traveled portion of the road. The trial court granted summary judgment in favor of Defendants, concluding that they owed no duty of care to Plaintiff. The court of appeals affirmed. On appeal, Defendants asked the Supreme Court to hold that an adjacent landowner owes a duty of care to a motorist who unintentionally strays from the regularly traveled portion of the road if the landowner has consciously created a hazard in the right-of-way with knowledge of the danger it would present to such a motorist. The Supreme Court declined to do so and affirmed, holding that Defendants did not owe Plaintiff a duty of care with respect to their mailbox. View "Snay v. Burr" on Justia Law