Justia Ohio Supreme Court Opinion Summaries

George Martens filed a complaint in the Third District Court of Appeals for a writ of mandamus against various judges and courts in Hancock County, alleging that they lacked jurisdiction to decide certain tax cases. Martens did not allege that he was a party to any tax case pending before those courts when he filed this action. The judges and courts filed a motion to dismiss, arguing that Martens lacked standing and had not stated a cognizable mandamus claim.The Third District Court of Appeals dismissed the case, concluding that Martens lacked standing to bring the complaint and had failed to state a claim for mandamus relief. Martens appealed to the Supreme Court of Ohio, arguing that he did not need to meet the traditional standing requirement based on the public-right doctrine recognized in State ex rel. Ohio Academy of Trial Lawyers v. Sheward. Alternatively, he claimed taxpayer standing.The Supreme Court of Ohio rejected Martens's reliance on Sheward, overruling the public-right doctrine established in that case. The court held that Sheward was contrary to the deeply rooted standing requirement and the Ohio Constitution. The court also found that Martens could not establish taxpayer standing, as he had not shown any special interest in the public funds at issue or cited statutory authority authorizing him to bring a taxpayer suit. Consequently, the Supreme Court of Ohio affirmed the Third District's dismissal of Martens's complaint for lack of standing. View "State ex rel. Martens v. Findlay Municipal Court" on Justia Law

The City of Rittman filed an original action in prohibition against Judge Corey E. Spitler of the Wayne County Common Pleas Court. Rittman sought to prevent Judge Spitler from exercising jurisdiction over a class-action lawsuit in which Rittman was named as a defendant. The lawsuit, filed by Tara Boler and Trista Bise, alleged that Rittman had illegally collected a 0.5 percent income tax increase beyond its authorized period and sought refunds for the overcharged taxes from 2008 to 2022.In the Wayne County Common Pleas Court, Judge Spitler denied Rittman’s motion to dismiss and motion to stay discovery, and he established a case-management schedule. Rittman then sought a writ of prohibition from the Supreme Court of Ohio to stop Judge Spitler from proceeding with the case, arguing that the lawsuit was an impermissible attempt to bypass the statutory process for obtaining tax refunds.The Supreme Court of Ohio reviewed the case and determined that Judge Spitler had jurisdiction and statutory authority under R.C. 2723.01 to hear the case. The court found that the plaintiffs' claims were substantively governed by R.C. 2723.01, which allows common pleas courts to enjoin the illegal levy or collection of taxes and entertain actions to recover them when collected. The court concluded that although the plaintiffs did not explicitly invoke R.C. 2723, their claims fit within its scope. Therefore, the Supreme Court of Ohio denied the writ of prohibition, allowing Judge Spitler to continue exercising jurisdiction over the underlying case. View "State ex rel. Rittman v. Spitler" on Justia Law

In this case, Claudia Kennedy, as the executor of Donald R. Gerres's estate, filed a medical malpractice lawsuit against Western Reserve Senior Care and Dr. Sataya Acharya, among others, alleging that substandard medical care led to Gerres's death in October 2013. Kennedy initially filed the lawsuit in September 2014, voluntarily dismissed it in January 2019, and refiled it within a year.The trial court denied the healthcare providers' motion for judgment on the pleadings, which argued that the four-year statute of repose for medical claims barred Kennedy's refiled action. However, after the Ohio Supreme Court's decision in Wilson v. Durrani, which held that the saving statute does not preserve claims refiled after the statute of repose expires, the healthcare providers sought summary judgment. The trial court denied this motion but later granted a directed verdict in favor of the healthcare providers after Kennedy's opening statements.Kennedy appealed to the Eleventh District Court of Appeals, arguing that R.C. 2305.15(A) tolled the statute of repose because Dr. Acharya had moved out of Ohio. The Eleventh District affirmed the trial court's decision, holding that applying the tolling statute to Dr. Acharya, who left Ohio for legitimate business purposes, violated the dormant Commerce Clause.The Supreme Court of Ohio reviewed the case and held that R.C. 2305.15(A) does not violate the dormant Commerce Clause as applied to a physician who moved out of Ohio to practice medicine in another state. The court found that the tolling statute serves a legitimate local purpose and does not impose a burden on interstate commerce that is clearly excessive in relation to its benefits. The judgment of the Eleventh District Court of Appeals was reversed, and the case was remanded to the trial court for further proceedings. View "Kennedy v. W. Res. Senior Care" on Justia Law

The case involves Patricia A. Heilman, the surviving spouse of Arthur J. Heilman, who died from an industrial accident. Patricia Heilman sought scheduled-loss compensation under Ohio law, claiming her husband had lost the use of both arms, both legs, sight in both eyes, and hearing in both ears before his death. The Industrial Commission of Ohio denied her request based on a nonexamining physician's report, which did not fully accept the findings of the examining physicians.The Tenth District Court of Appeals reviewed the case and granted a limited writ of mandamus. The court ordered the Industrial Commission to vacate its denial of scheduled-loss compensation and to re-evaluate whether Patricia Heilman had established her claims under the relevant statute. The court found that the Commission had improperly relied on the nonexamining physician's report, which did not comply with the requirements set forth in Wallace v. Industrial Commission.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District's judgment. The court held that the Industrial Commission abused its discretion by relying solely on the nonexamining physician's report, which failed to accept the objective findings of the examining physicians. The Supreme Court clarified that while the Commission could not base its decision solely on the nonexamining physician's report, it could use the report as guidance in evaluating the remaining medical evidence. The court ordered the Commission to vacate its previous order and issue a new decision based on a proper evaluation of the evidence. View "State ex rel. Heilman v. Industrial Commission" on Justia Law

The City of Obetz initiated a mandamus and prohibition action against Franklin County Auditor Michael Stinziano and Franklin County Treasurer Cheryl Brooks Sullivan. The dispute arose from a tax-increment-financing (TIF) arrangement established by Obetz in 1997. Obetz erroneously received TIF proceeds in 2015, 2016, and 2017. To correct this, Obetz returned some funds to the county, but the county also withheld Obetz's real-property-tax distribution for the first half of 2022 and reallocated it to other taxing jurisdictions.The Franklin County Court of Common Pleas initially reviewed the case, where Obetz sought to compel the county to return the funds it had tendered and to pay future settlement distributions without setoff. The lower court's decision led to the current appeal.The Supreme Court of Ohio reviewed the case. The court held that Obetz was not entitled to the return of the $212,963.01 it had voluntarily paid to the county. Additionally, the court denied Obetz's request for the county to pay $194,944.32, which had been withheld and reallocated to other jurisdictions. However, the court granted a limited writ of mandamus, compelling the county to pay future settlement distributions to Obetz without setoff. The court found that the county did not have the authority under R.C. 319.44, R.C. 323.133(B), R.C. 5713.08, or R.C. 5715.22 to withhold future settlement funds from Obetz. The court also denied Obetz's request for a writ of prohibition, as the county's actions did not constitute the exercise of judicial power. View "State ex rel. Obetz v. Stinziano" on Justia Law

Christopher R. Hicks submitted a public-records request to the Union Township, Clermont County Board of Trustees, seeking email- and mail-distribution lists for the township's newsletter. The township denied the request, claiming the lists did not document the township's activities and were not public records. Hicks filed a complaint in the Court of Claims, arguing that the lists were public records documenting the township's functions and activities.The Court of Claims appointed a special master who found that the lists were used for administrative convenience and did not meet the definition of a public record. The Court of Claims adopted this recommendation and denied Hicks's request. Hicks appealed to the Twelfth District Court of Appeals, which affirmed the lower court's decision, agreeing that the lists were used solely for convenience and did not document the township's functions or activities.The Supreme Court of Ohio reviewed the case and reversed the lower court's decision. The court held that the email- and mail-distribution lists are public records under R.C. 149.011(G) because they document the township's functions and activities by showing how the newsletter is distributed to constituents. The court emphasized that the Public Records Act should be construed liberally in favor of broad access and that the lists are central to the township's communication with its constituents. The court ordered that the requested records be made available to Hicks. View "Hicks v. Union Twp. Clermont Cty. Bd. of Trustees" on Justia Law

The case involves a dispute between Ohio Edison Company and the Corder family over the use of herbicides on property subject to easements held by Ohio Edison. The easements, granted in 1948, allow Ohio Edison to maintain electrical transmission lines and to trim, cut, and remove trees, limbs, underbrush, or other obstructions that may interfere with or endanger their infrastructure.Initially, the trial court dismissed the case for lack of jurisdiction, believing it fell under the exclusive jurisdiction of the Public Utilities Commission of Ohio. The Seventh District Court of Appeals reversed this decision, holding that the trial court had jurisdiction and remanded the case to resolve the ambiguity in the easements. The Ohio Supreme Court affirmed the appellate court's jurisdictional ruling but vacated its analysis of the easements, remanding the case to the trial court.On remand, the trial court granted summary judgment to the Corders, holding that the easements did not permit the use of herbicides. The Seventh District Court of Appeals affirmed this decision, finding the easements ambiguous and concluding that they did not authorize the use of herbicides.The Supreme Court of Ohio reviewed the case and determined that the easements unambiguously grant Ohio Edison the right to remove vegetation and other obstructions. The court held that the term "remove" includes the use of herbicides, as the easements do not restrict the methods of removal. Consequently, the Supreme Court reversed the appellate court's judgment and remanded the case to the trial court to issue an entry awarding summary judgment to Ohio Edison. View "Corder v. Ohio Edison Co." on Justia Law

The case involves the termination of a police chief, Erica Barga, by the Village Council of St. Paris. Barga was placed on administrative leave by the mayor, who filed charges against her for insubordination and neglect of duty. Barga requested a public hearing to address these charges. The village council conducted the hearing in public but deliberated in executive session before voting to terminate Barga's employment.The Champaign County Court of Common Pleas upheld the village council's decision, concluding that Barga did not have a substantive or procedural right to have the entire disciplinary hearing open to the public. The court also found that the village council's decision was presumed valid and that Barga had not overcome this presumption.The Second District Court of Appeals affirmed the lower court's decision regarding the Open Meetings Act, relying on a federal district court decision that exempted quasi-judicial proceedings from the Act. However, it found that the common pleas court had applied the wrong standard of review and remanded the case for a de novo review.The Supreme Court of Ohio reversed the court of appeals' decision, holding that the village council violated the Open Meetings Act by deliberating in executive session after Barga requested a public hearing. The court emphasized that the plain terms of the Act required the council to consider the charges in a public hearing. The court remanded the case to the village council for a public hearing in compliance with the Open Meetings Act. View "Barga v. St. Paris Village Council" on Justia Law

Tommy Glover committed a series of armed robberies and kidnappings in May and June 2020, resulting in his convictions for 11 first-degree felonies and six gun specifications. Glover's crimes involved holding victims at gunpoint, forcing them to withdraw money from ATMs, and causing significant emotional trauma. The trial court sentenced Glover to an aggregate term of 60 years in prison, with some sentences running consecutively and others concurrently.The First District Court of Appeals reversed the trial court's sentence, finding it disproportionate to Glover's criminal history, the danger he posed, and the offenses committed. The appellate court modified Glover's sentences to run concurrently, resulting in a reduced aggregate sentence of 25 years. The court of appeals based its decision on the lack of physical harm to the victims and compared Glover's sentence to those in other cases involving both physical and emotional harm.The Supreme Court of Ohio reviewed the case and found that the appellate court erred in its analysis. The Supreme Court emphasized that the appellate-review statute limits the appellate court's review to whether the trial court's findings under R.C. 2929.14(C)(4) are clearly and convincingly unsupported by the record. The Supreme Court concluded that the trial court's findings were supported by substantial evidence, including the severe emotional harm inflicted on the victims and Glover's lack of remorse. The Supreme Court reversed the appellate court's judgment and reinstated the trial court's original sentence of 60 years. View "State v. Glover" on Justia Law

The case involves a group of relators seeking to place a proposed constitutional amendment titled "Ohio Voters Bill of Rights" before Ohio voters. The relators submitted the text and a summary of their proposed amendment to the Ohio Attorney General, Dave Yost, for certification. The Attorney General refused to certify the summary, arguing that the title "Ohio Voters Bill of Rights" was not a fair and truthful statement of the proposed amendment.Previously, the relators had submitted their petition with a different title, "Secure and Fair Elections," which the Attorney General also rejected for similar reasons. The relators revised their petition and resubmitted it with the new title, but the Attorney General again refused to certify it, focusing solely on the title's perceived inaccuracy.The Supreme Court of Ohio reviewed the case. The court determined that the Attorney General's authority under R.C. 3519.01(A) is limited to examining the summary of a proposed constitutional amendment, not its title. The court found that the Attorney General exceeded his statutory authority by rejecting the petition based on the title. The court noted that the statutory scheme differentiates between a "summary" and a "title," and the Attorney General's duty is to review only the summary.The Supreme Court of Ohio granted a limited writ of mandamus, ordering the Attorney General to examine the summary of the relators' proposed amendment within ten days, determine whether it is a fair and truthful statement, and, if so, certify and forward the petition to the Ohio Ballot Board. The court emphasized that the Attorney General must perform his statutory duty without considering the title of the proposed amendment. View "State ex rel. Dudley v. Yost" on Justia Law