Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court dismissing Plaintiffs' complaint seeking an injunction halting their execution and a declaration that the Department of Rehabilitation and Correction's (DRC) written execution protocol was invalid, holding that there was no error.Plaintiffs were two condemned inmates who challenged the DRC's written execution protocol setting forth the specific process by which DRC personnel are to carry out death sentences by lethal injection. Specifically, Plaintiffs argued (1) DRC may adopt the execution protocol only by following the procedures for promulgating it as an administrative rule, in accordance with Ohio Rev. Code 111.15(B); and (2) until these procedures were followed, the protocol was invalid and could not be used to carry out death sentences. The trial court granted summary judgment for the State, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the execution protocol was neither a rule having a general and uniform application nor an internal management rule; and (2) therefore, the protocol was not subject to the rule-making requirements of Ohio Rev. Code 111.15. View "O'Neal v. State" on Justia Law

The Supreme Court reversed the decision of the Public Utilities Commission of Ohio (PUCO) granting certification to FirstEnergy Advisors, a competitive retail electric service provider, holding that the order in this case fell short of the requirement set forth in Ohio Rev. Code 4903.09 that PUCO file "findings of fact and written opinions setting forth the reasons prompting the decisions arrived at."Two organizations in this case intervened in the PUCO proceedings and objected to the certification. Despite the objections, PUCO granted the certification request and issued a "barebones" order offering no explanation as to how FirstEnergy Advisors met the applicable legal requirements. The Supreme Court reversed PUCO's certification decision and remanded the matter to PUCO for further proceedings, holding that PUCO's order violated action 4903.09 because it failed to explain the reasoning and factual grounds for granting FirstEnergy Advisors' application. View "In re Application of FirstEnergy Advisors for Certification as a Competitive Retail Electric Service Power Broker & Aggregator" on Justia Law

The Supreme Court denied Relator's request seeking a writ of mandamus ordering the public-records officer for the Ohio Adult Parole Authority (APA) to produce records that Relator claimed to have requested under Ohio's Public Records Act, Ohio Rev. Code 149.43, holding that Relator was not entitled to the writ.In his mandamus action, Relator alleged that he sent a public-records request to the APA's public-records officer seeking public records from the personnel files of six Ohio Parole Board members who were members of the panel for Relator's parole hearing and that the officer had not responded to his request. The Supreme Court denied mandamus relief, holding that because Relator failed to provide evidence to demonstrate that he delivered the alleged public-records request to the APA at all, Relator was not entitled to relief in mandamus. View "State ex rel. Griffin v. Doe" on Justia Law

The Supreme Court denied the writ of mandamus sought by Relator, an inmate at the Toledo Correctional Institution (TCI), to compel Respondent, the public-records custodian, to provide the names of five inmates who were allegedly murdered at TCI between 2012 and 2014, holding that Relator failed to show that he had requested an existing record.Relator filed this original action seeking a writ of mandamus to compel Respondent to produce records in response to requests, alleging that a policy required the creation of incident reports concerning any murders that occur within a prison. The Supreme Court denied the writ, holding that Relator was not entitled to relief because requests that require the records custodian to create a new record by searching for selected information are improper requests under Ohio Rev. Code 149.43. View "State ex rel. Griffin v. Sehlmeyer" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition to vacate his murder conviction, holding that the court of appeals was correct to dismiss Appellant's claim.Appellant was convicted of murder in 2014. In 2020, Appellant filed a complaint for writs of mandamus and prohibition in the court of appeals against Judge Daniel Hogan, the now-retired judge who presided over his criminal case, alleging that his conviction must be vacated because Judge Hogan committed "fraud." The court of appeals dismissed the complaint. The Supreme Court affirmed, holding (1) the court of appeals correctly dismissed Appellant's complaint; and (2) Appellant's motion for judicial notice is denied. View "State ex rel. Jones v. Hogan" on Justia Law

The Supreme Court affirmed Defendant's sentences of death imposed in connection with his convictions of four counts of aggravated murder with multiple death specifications as to each count, holding that each of Defendant's four death sentences were appropriate and proportionate.After a trial, Defendant was found guilty of four counts of aggravated robbery and other crimes. Defendant was sentenced to death on all four counts of aggravated murder. The Supreme Court affirmed, holding (1) the trial court did not deny Defendant due process by not ordering a competency hearing sua sponte; (2) Defendant's claims that both his jury waiver and his subsequent guilty pleas were invalid because they were not knowing, voluntary, and intelligent were unavailing; (3) Defendant's trial court rendered constitutionally effective assistance; and (4) in sentencing Defendant, the court did not improperly weigh nonstatutory aggravating circumstances against him or improperly discount the mitigating factors. View "State v. Lawson" on Justia Law

The Supreme Court held that a provision found in just about every commercial and personal-property insurance policy issued in Ohio that bars coverage for damage caused by "water that backs up or overflows from a sewer" includes damage caused by sewage carried into an insured property by a backup or overflow event.Sewage from the local sewer system backed up into the Bank Nightclub, a bar that was insured at the time by United Specialty Insurance Company. The bar subsequently hired Cleantech to clean up the site and submitted a claim to its insurer. United Specialty denied the claim, citing an exclusion in the bar's policy for damage caused by water that backs up or overflows from a sewer. The bar assigned AKC any claims it might have against United Specialty, and AKC then brought this breach of contract claim. The trial court granted summary judgment in favor of United Specialty. The court of appeals reversed. The Supreme Court reversed, holding that the water-backup exclusion in the policy included damage caused by the sewage. View "AKC, Inc. v. United Specialty Insurance Co." on Justia Law

The Supreme Court vacated the judgment of the Tenth District Court of Appeals granting a writ of mandamus ordering the Industrial Commission of Ohio to vacate its order granting temporary total disability (TTD) compensation to Bridget Moss and then granted a limited writ, holding that the Commissioner must reconsider this case under the proper standard, as articulated in this opinion.Moss's employer, Ryan Alternative Staffing, Inc. (Ryan) sought a writ of mandamus ordering the Commission to vacate its order and deny TTD compensation because Moss had refused an offer of alternative employment within her medical restrictions. The Tenth District granted the writ. At issue on appeal was whether the Commission may award TTD compensation if an employee refuses an offer of alternative employment in good faith based on family circumstances. The Supreme Court vacated the Tenth district's judgment and granted a limited writ, holding that the Commission's orders exhibited confusion about the correct standard under which the employer's good faith standard was to be determined. View "State ex rel. Ryan Alternative Staffing, Inc. v. Moss" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's complaint seeking a writ of mandamus to compel the Cuyahoga County Court of Common Pleas to rule on Appellant's motion to reinstate bail and to set bail terms, holding that there was no error.Appellant was being held in the Cuyahoga County jail where he awaited trial on criminal charges in two cases. In Appellant's first criminal case, the trial court set bail at $5,000. Appellant posted ten percent of that amount and was released. In Appellant's second criminal case, the trial court set bail in the amount of $100,000 and revoked Appellant's bail in the first case based on his failure to appeal at a pretrial hearing. Appellant sought to have his bail reinstated, but the trial court denied relief. Appellant then filed a complaint for a writ of mandamus asking the court of appeals to issue an order compelling the trial court to rule on his motions and to set bail conditions that would allow for his pretrial release in his first case. The court of appeals denied relief. The Supreme Court affirmed, holding that Appellant's claim did not lie in mandamus. View "State ex rel. Wesley v. Cuyahoga County Court of Common Pleas" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing this appeal of a decision of the Ohio State Board of Education, holding that the state board's final determination that a charter school must repay approximately $60 million in excess funding could not be appealed under Ohio Rev. Code Chapter 119.In 2016, the Ohio Department of Education determined that the state had overpaid the Electronic Classroom of Tomorrow (ECOT), formerly Ohio's largest charter school, approximately $60 million based on a review of the school's enrollment data. ECOT appealed under Ohio Rev. Code 3314.08(K)(2)(b), which allows a charter school to appeal such a decision to the board of education for an informal hearing. The state board confirmed the department of education's determination. At issue was whether ECOT could appeal the board of education's "final" decision where section 3314.08(K)(2)(d) provides that any decision made by the board on such an appeal is final. The Supreme Court concluded that ECOT had no right to appeal the decision under Ohio Rev. Code Chapter 119. View "Electronic Classroom of Tomorrow v. State Board of Education" on Justia Law