Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that the court of appeals properly dismissed the petition.Appellant was convicted on multiple counts of rape, kidnapping, and felonious assault and sentenced to an aggregate prison term of 104 to 155 years. In his habeas corpus petition, Appellant asserted that the prosecution had committed a Brady violation and that the trial court erred in denying his motion for a new trial. The court of appeals dismissed the petition on the grounds that Appellant had failed to comply with Ohio Rev. Code 2969.25(C) and that the petition failed to state a valid habeas claim. The Supreme Court affirmed, holding that the court of appeals erred in dismissing the petition for failure to comply with section 2969.25(C) but was correct to dismiss the petition for failure to state a valid habeas claim. View "Davis v. Hill" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing a decision of the Belmont County Court of Common Pleas and holding that amicus curiae Guernsey County Community Development Corporation (CDC) had violated land transfer restrictions that were included in a deed under the CDC's grant agreement with the Ohio Public Works Commission (OPWC), holding that there was no error.OPWC appealed the trial court's judgment that the deed restrictions did not apply to the subsurface of the property and the trial court's earlier holding denying OPWC's motion for an injunction. The court of appeals reversed, concluding that the transfer restriction in the deed applied to both the surface and subsurface rights of the property and that OPWC had the authority to seek equitable remedies. The Supreme Court affirmed, holding (1) the CDC violated enforceable land transfer restrictions included in the deed and thus violated the terms of CDC's grant agreement with the OPWC; and (2) OPWC was entitled to seek remedies at law and in equity to conserve the land for its intended purpose. View "Siltstone Resources, LLC v. Ohio Public Works Commission" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus ordering the Cuyahoga County Clerk of Courts to produce various records relating to criminal proceedings against Parker Bey in the Cuyahoga County Court of Common Pleas, holding that Bey was not entitled to relief.Twice, the court of appeals denied Bey a writ of mandamus. After the first denial of the writ, the Supreme Court held that the court of appeals erred in applying the Ohio Rules of Superintendence as a basis for denying mandamus relief and remanded for a determination as to whether Bey was entitled to relief under the Public Records Act, Ohio Rev. Code 149.43. On remand, the court of appeals again denied the writ. The Supreme Court affirmed, holding that the court of appeals did not err in denying the writ. View "State ex rel. Bey v. Byrd" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus or procedendo, holding that Appellant was not entitled to the writ.In 1992, Appellant was convicted of aggravated murder and sentenced to life imprisonment. In 2021, Appellant filed an action for writs of prohibition and mandamus seeking to have his sentence declared void because Judge Thomas Nurre erroneously imposed costs and fines. The court of appeals granted the motion to dismiss filed by the common pleas court and clerk. The Supreme Court affirmed, holding that this case fell within the general rule that a mandamus action is not an appropriate vehicle for challenging sentencing errors. View "State ex rel. Harris v. Hamilton County Clerk of Courts" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court issuing a new sentencing entry that included a required notification as to the postrelease-control portion of Defendant's sentence, holding that holding that the trial court's new sentencing entry was improper.In 2008, Defendant was sentenced to a nine-year prison term for his convictions of kidnapping, rape, and robbery. The trial court failed to include in Defendant's sentencing entry a statement that postrelease control was mandatory. In 2018, the trial court issued a new sentencing entry that included a notification that postrelease control was mandatory and that a violation of postrelease control would subject Defendant to the consequences set forth in Ohio Rev. Code 2967.28. The court of appeals affirmed. The Supreme Court vacated the portion of the 2018 sentencing entry imposing postrelease control, holding (1) res judicata precluded the State's collateral attack on Defendant's sentence; and (2) therefore, the trial court's sentencing entry was improper and of no effect. View "State v. Bates" on Justia Law

The Supreme Court reversed in part the judgment of the Board of Tax Appeals (BTA) abating a tax penalty imposed against Appellee by the Tax Commissioner of Ohio, holding that the BTA's abatement of the penalty was clearly erroneous.The tax commissioner assessed unpaid tax in the amount of $4,821 as against Appellee and exercised his statutory discretion to impose a fifteen percent penalty amounting to $723. The BTA upheld the tax assessment against Appellee but found that the tax commissioner had abused his discretion in assessing a penalty. The Supreme Court reversed in part, holding that the BTA's holding that the tax commissioner abused his discretion and that the BTA's order abating the penalty were clearly erroneous. View "Karr v. McClain" on Justia Law

The Supreme Court granted the original actions filed in this Court seeking a writ of mandamus and a writ of prohibition to compel Judge Megan E. Shanahan to allow M.R. to proceed in a lawsuit using a pseudonym and partially sealing M.R.'s affidavit at his request, holding that Judge Shanahan abused her discretion by allowing M.R. to proceed using a pseudonym.M.R., a Cincinnati police officer using a pseudonym, filed a complaint for injunctive relief alleging that Defendants, several people, had publicly made the false claim that he was a white supremacist. M.R. filed a motion for a temporary restraining order and an affidavit in support of the motion along with his complaint. Judge Shanahan granted the request. Relators, the Cincinnati Enquirer and Eugene Volokh, filed separate actions seeking access to M.R.'s affidavit and to prevent Judge Shanahan from continuing to permit M.R. to use a pseudonym. The Supreme Court granted the writs, holding that M.R.'s privacy interests did not substantially outweigh the presumption of open judicial proceedings. View "State ex rel. Cincinnati Enquirer v. Shanahan" on Justia Law

In this case involving two separate deeds to property in which successive grantors conveyed the surface rights and part of the mineral interest while retaining part of the oil and gas rights the Supreme Court affirmed in part and reversed in part the judgment of the court of appeals, holding that the court of appeals erred in part.Both deeds at osier were executed before 1925 and did not contain words of inheritance. The lower courts concluded that the conveyances created reservations of the oil and gas rights that retained life estates in those rights expiring on the respective deaths of the grantors. The court of appeals affirmed summary judgments in favor of Appellees - Peppertree Farms, LLC and Jay and Amy Moore - and quieting title to the oil and gas rights claimed by Appellants - KOAG, Inc., Richard Reinholtz, and Sylvia Ann Miller. The court further concluded that Miller's and Reinholtz's interests - but not KOAG's - would have been extinguished by operation of the Marketable Title Act, Ohio Rev. Code 5301.47 et seq. The Supreme Court reversed in part, holding words of inheritance were not required to retain more than a life estate in excepted interests in the oil and gas; and (2) summary judgment against KOAG was erroneous. View "Peppertree Farms, L.L.C. v. Thonen" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that a recorded will that does not affect title to an interest in land is not a recorded title transaction under Ohio Rev. Code 5301.47(F) and cannot be an exception to the Marketable Title Act under Ohio Rev. Code 5301.49, holding that the court of appeals did not err.Specifically, the Supreme Court held (1) the trial court and the appellate court incorrectly concluded that the interest H.J. Jones retained in the oil and gas was a life estate that expired upon Jones's death in 1932; but (2) the lower courts did not err in determining that a recorded will that does not distribute the decedent's oil and gas rights does not affect title and is not a recorded title transaction preventing those rights from being extinguished. View "Peppertree Farms, L.L.C. v. Thonen" on Justia Law

The Supreme Court denied a writ of habeas corpus ordering Petitioner's release from the Lorain Correctional Institution where Jennifer Black was the warden, holding that Petitioner was not entitled to relief in habeas corpus.Petitioner was convicted of sexual battery and gross sexual imposition. After Petitioner was released from prison the Adult Parole Authority found that Petitioner had violated the terms of his postrelease control and imposed a prison term. Petitioner commenced this action seeking his release. The Supreme Court denied the writ, holding that Petitioner's argument did not state a valid claim for relief in habeas corpus. View "Simmons v. Black" on Justia Law