Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals affirming Appellant's conviction and vacated the conviction, holding that no adult court had jurisdiction over acts that were charged in but not bound over by the juvenile court.Appellant was sixteen years old when he was charged with committing the category-two offense of aggravated robbery while possessing a deadly weapon. Binding Appellant over to adult court would have been mandatory for counts one and two upon a finding of probable cause. The juvenile court found probable cause as to counts one through three and count five, a misdemeanor. After the case was transferred to the adult court, Appellant pled guilty to several charges. On appeal, Appellant argued that the adult court lacked jurisdiction to consider the charges for which the juvenile court found no probable cause. The Supreme Court reversed, holding that in the absence of a juvenile court's finding probable cause or making a finding that the juvenile is unalienable to care or rehabilitation within the juvenile system, no adult court has jurisdiction over acts that were charged in but not bound over by the juvenile court. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing two complaints for writs of mandamus to compel the Bureau of Sentence Computation (BSC) and the Ohio Adult Parole Authority (APA) to produce public records, holding that the court of appeals did not err.While he was an inmate, Appellant sent a public-records request to the BSC, which Appellant allegedly never responded to. After Appellant filed his complaint for a writ of mandamus he acknowledged receiving the requested documents but argued that he was entitled to statutory damages and court costs because the BSC did not timely produce the records. Appellant also filed a mandamus complaint challenging the APA's alleged lack of response to his public records request. The APA filed a motion to dismiss based on Appellant's alleged failure to comply with Ohio Rev. Code 2969.25(A). The court of appeals dismissed the cases for failure to comply with section 2969.25(A). The Supreme Court affirmed, holding that the court of appeals correctly dismissed both mandamus complaints. View "State ex rel. Bey v. Bureau of Sentence Computation" on Justia Law

The Supreme Court remanded this case to the trial court for modification of Defendant's conviction for rape of a child under the age of thirteen in violation of Ohio Rev. Code 2907.02(A)(1)(b) and for resentencing, holding that a conviction for rape based on insertion must be supported by evidence that the defendant inserted a body part or object into another.Defendant's arose from an incident in which she directed her son to insert a sex toy into her vagina and then filmed the act. On appeal, Defendant argued that a conviction for rape based on insertion must be supported by evidence that the defendant inserted a body part or object into another. The Supreme Court agreed and reversed and remanded the case, holding (1) there was insufficient to support Defendant's conviction for rape; but (2) there was sufficient evidence to sustain a conviction for gross sexual imposition, a lesser-included offense of rape. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting a writ ordering the Industrial Commission of Ohio to vacate its order awarding compensation to Cami Bowman, holding that the court of appeals correctly concluded that the Commission abused its discretion.Bowman sought compensation for the permanent partial loss of her sight based on a seventy percent bilateral loss of vision. The Commission awarded compensation based on only a forty-five percent loss of sight in the left eye, maintaining a prior award based on a sixty-seven percent loss of sight in the right eye. The court of appeals granted Bowman a writ ordering the Commission to vacate its order and award her requested compensation, ruling that the Commission abused its discretion by relying on a portion of a physician's report that the physician had disclaimed. The Supreme Court affirmed, holding that the Commission failed to base its decision on medical evidence. View "State ex rel. Bowman v. Industrial Commission" on Justia Law

The Supreme Court granted a writ of mandamus ordering the Gauge County auditor to issue warrants on the county treasurer to pay for court-ordered expenditures, holding that Timothy Grendell, judge of the Geauga County Common Pleas Court's juvenile and probate divisions, was entitled to the writ.Judge Grendell sought a writ of mandamus ordering Charles E. Walder, the Geauga County auditor, to issue warrants for five categories of expenditures relating to the juvenile and probate divisions of the Geauga County Common Pleas Court. The Supreme Court granted a writ of mandamus ordering Walder to issue warrants for payment of the contested expenditures, holding that Judge Grendell presented valid claims and that he was entitled to a writ of mandamus. View "State ex rel. Grendell v. Walder" on Justia Law

The Supreme Court denied Appellant's request for a writ of mandamus ordering Police Chief Michael Kilbane and the City of Independence (collectively, the City) to produce documents relating to the City's implementation of a traffic-ticket quota, holding that Appellant failed to show her entitlement to the writ.In addition to the writ, Appellant sought statutory damages, attorney fees, and costs. The Supreme Court denied Appellant's request for the writ, denied her requests for attorney fees and costs, and awarded her $1,000 in statutory damages, holding (1) the writ must be denied as to all of Appellant's requests; (2) because the City's delay in producing certain documents was unreasonable, Appellant was entitled to $1,000 in statutory damages; and (3) Appellant was not entitled to attorney fees or costs. View "State ex rel. Horton v. Kilbane" on Justia Law

The Supreme Court declared the congressional-district plan passed by the General Assembly invalid, holding that the General Assembly did not comply with Ohio Const. art. XIX, 1(C)(3)(a) and (b) in passing the plan and that a new congressional-district plan must be passed the complies in full with Article XIX and is not dictated by partisan considerations.At issue was 2021 Sub.S.B. No. 258, which was passed by a simple majority and signed into law by Governor Mike DeWine on November 20, 2021. The bill resulted in districts in which undue political bias was at least, if not more, likely to favor Republican candidates than the 2011 reapportionment that impelled Ohio's constitutional reforms. Petitioners argued that the congressional-district plan violated Article XIX, Section 1(C)(3)(a). The Supreme Court held that the congressional-district plan was invalid in its entirety because it unduly favored the Republican Party and disfavored the Democratic Party and because it unduly split three counties, in violation of Article XIX, Section 1(C)(3)(b). View "Adams v. DeWine" on Justia Law

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