Justia Ohio Supreme Court Opinion Summaries

In January 2020, Sontez Sheckles was indicted in Hamilton County Common Pleas Court for attempted murder, felonious assault, and having a weapon while under a disability, stemming from an alleged shooting at a bar. The prosecution intended to call a former federal prosecutor, Zachary Kessler, as a witness and present an edited video of the incident. However, the trial court excluded Kessler's testimony due to the absence of a Touhy letter authorizing him to testify and excluded the video because the bar owner could not authenticate it.The State appealed these rulings to the First District Court of Appeals, arguing that the trial court's decisions had weakened its case to the point of destroying any reasonable possibility of effective prosecution. The First District affirmed the trial court's rulings, agreeing that the absence of a Touhy letter justified excluding Kessler's testimony and that the video could not be authenticated by the bar owner.The State then appealed to the Supreme Court of Ohio, which reviewed whether the Touhy regulations should have been used to prevent Kessler from testifying and whether the trial court's pretrial evidentiary rulings should have been considered preliminary. The Supreme Court of Ohio held that Touhy regulations do not create rights for criminal defendants and cannot be used to exclude testimony from a willing and authorized federal employee. The court reversed the First District's judgment on the Touhy issue and remanded the case to the trial court for further proceedings. The court did not address the finality of the trial court's pretrial evidentiary rulings, vacating that portion of the First District's judgment. View "State v. Sheckles" on Justia Law

The case involves a medical negligence claim brought by Janet Hild, the administrator of Scott Boldman's estate, against several medical professionals and entities, including Samaritan Health Partners and Good Samaritan Hospital. Boldman, who had multiple health issues, underwent an emergency appendectomy at Good Samaritan Hospital. Post-surgery, he became combative and removed his breathing tube, after which he soon died. Hild claimed that the anesthesia was improperly handled, causing Boldman's aggressive behavior and subsequent death. The hospital argued that Boldman self-extubated and suffered a cardiac arrest unrelated to the anesthesia.The case proceeded to a jury trial in the Montgomery County Court of Common Pleas. The jury found that Sandra Ward, the Certified Registered Nurse Anesthetist, was negligent in her care of Boldman. However, only the six jurors who found negligence were allowed to vote on whether Ward's negligence proximately caused Boldman's death. They concluded it did not. Hild filed a motion for a new trial, arguing that all jurors should have been allowed to vote on proximate cause. The trial court denied the motion.The Second District Court of Appeals reversed the trial court's decision in part, holding that the trial court erred by not allowing all jurors to vote on proximate cause, and remanded the case for a new trial on specific issues. The hospital appealed to the Supreme Court of Ohio.The Supreme Court of Ohio held that the same-juror rule applies in all negligence cases where the jury answers sequential interrogatories that separate the elements of negligence. This means the same three-fourths of jurors must concur on all elements for a valid verdict. The court reversed the Second District's decision to the extent it ordered a new trial and reinstated the jury's verdict in favor of the hospital. View "Hild v. Samaritan Health Partner" on Justia Law

The relator, Justin Tjaden, sought a writ of mandamus to have his name placed on the November 5, 2024, general-election ballot as an independent candidate for the office of state representative of Ohio House District 99. Tjaden's petition was found to be 124 valid signatures short of the required number. He argued that the boards of elections exceeded their authority by invalidating signatures as "not genuine" and violated his procedural due process and equal protection rights. Tjaden also contended that the statutory requirement for independent candidates to submit a petition with signatures amounting to at least one percent of registered voters who cast ballots for governor in the 2022 general election was unconstitutional.The Geauga County Board of Elections determined that Tjaden's petition contained 371 valid signatures, which was insufficient to qualify for the ballot. Tjaden attempted to challenge this decision in the Geauga County Court of Common Pleas but was unsuccessful due to procedural issues. He then filed a complaint in the same court and a mandamus action in the Supreme Court of Ohio. The Supreme Court dismissed his first mandamus action based on the jurisdictional-priority rule but allowed him to file a second mandamus action after his common-pleas-court case was removed to federal court.The Supreme Court of Ohio denied Tjaden's writ of mandamus. The court held that Tjaden did not have enough valid signatures to qualify for the ballot, even if all contested signatures were deemed valid. The court also found that Tjaden's procedural due process rights were not violated, as the mandamus action provided him with the necessary process. Additionally, the court declined to address Tjaden's equal protection claim, stating that even if the statute were declared unconstitutional, there would be no statutory requirement for an independent candidate to qualify for the ballot. Thus, the court denied the writ. View "State ex rel. Tjaden v. Geauga County Board of Elections" on Justia Law

In this case, Dean and Dave Cook filed a complaint with the Union County Board of Revision in February 2022, seeking an increase in the property valuation of an apartment complex owned by The Residence at Cooks Pointe, L.L.C. The Marysville Exempted Village Schools Board of Education filed a counter-complaint in May 2022, supporting the Cooks' claim that the property was undervalued. The Board of Revision held a hearing in August 2022 and decided not to change the property valuation due to insufficient evidence.The Marysville Exempted Village Schools Board of Education appealed the Board of Revision's decision to the Board of Tax Appeals (BTA) in September 2022. However, the BTA dismissed the appeal in December 2022, citing a recent amendment to R.C. 5717.01, effective July 21, 2022, which restricted the ability of school boards to appeal property valuation decisions unless they owned or leased the property in question. The school board then appealed to the Third District Court of Appeals, which reversed the BTA's decision, ruling that the amendment did not apply to cases pending before the Board of Revision when the amendment took effect.The Supreme Court of Ohio reviewed the case and affirmed the Third District Court of Appeals' decision. The court held that the amended R.C. 5717.01, which limits a political subdivision's ability to appeal a county board of revision's property valuation decision, does not apply to cases that were pending before a board of revision when the amendment took effect. The court emphasized that the language of the amended statute is written in the present tense and ties the right of appeal to the moment a complaint is filed with a board of revision. Therefore, the school board's appeal to the BTA should be considered under the former version of R.C. 5717.01. The case was remanded to the BTA for further proceedings. View "Marysville Exempted Village Schools Bd. of Edn. v. Union Cty. Bd. of Revision" on Justia Law

Vanessa Wells, a parent in the Lakota Local Schools district, filed a public records request seeking legal documentation related to the district's superintendent, Matt Miller, from the law firm of Elizabeth Tuck. Wells was concerned about allegations against Miller. The district's attorney, Brodi Conover, responded by providing a cease-and-desist letter but withheld other documents. Wells clarified her request to include all communications between Tuck and the school board regarding Miller from September 2022 to January 2023. Conover responded that certain communications were privileged and not subject to disclosure.Wells also requested all legal invoices from January 2022 to January 2023. Conover provided redacted invoices, omitting attorney names, hours, rates, and service descriptions, citing attorney-client privilege. In September 2023, after Wells filed a mandamus action, the district provided less-redacted invoices, retaining only the narrative descriptions and bank-account-related information.The Supreme Court of Ohio reviewed the case. It granted a writ of mandamus ordering the district to produce a demand letter from Tuck, rejecting the district's argument that it was protected under a federal settlement privilege. The court found that the district's reliance on Goodyear Tire & Rubber Co. v. Chiles Power Supply, Inc. was misplaced. The court awarded Wells $2,000 in statutory damages for the district's failure to timely produce the demand letter and the improperly redacted invoices. The court also awarded some attorney fees and court costs to Wells but denied additional attorney fees related to the invoices, finding no evidence of bad faith by the district. View "State ex rel. Wells v. Lakota Local Schools Board of Education" on Justia Law

Alphonso Mobley Jr. requested public records from the Hamilton County Prosecutor's Office, specifically certified statements created under former R.C. 309.16 for 2016 through 2020 and the office’s records-retention schedule. When Mobley did not receive a response, he filed a mandamus action to compel the production of these records and sought statutory damages under the Public Records Act, R.C. 149.43.The Supreme Court of Ohio previously issued a limited writ of mandamus, ordering the prosecutor to either provide the requested records or certify that they do not exist. The prosecutor complied by certifying that all responsive records in her possession were provided to Mobley on April 20, 2023. Additionally, the prosecutor obtained and provided records from the Hamilton County Board of County Commissioners that were not retained by her office. Mobley then filed a motion to proceed to judgment on the issue of statutory damages.The Supreme Court of Ohio determined that the prosecutor failed to comply with R.C. 149.43(B) by not responding to Mobley’s request within a reasonable period. The court noted that the request was narrow, involved few records, and did not require redactions. The prosecutor’s delay of almost three months was deemed unreasonable. Consequently, the court awarded Mobley $400 in statutory damages, calculated at $100 per business day for the four business days between the filing of the mandamus action and the prosecutor’s compliance. View "State ex rel. Mobley v. Powers" on Justia Law

In 1976, Prince Charles Cotten Sr. was convicted of aggravated murder and sentenced to death. The conviction included specifications for killing a police officer while attempting to escape apprehension. Following the United States Supreme Court's decision in Lockett v. Ohio, which declared Ohio's death-penalty statute unconstitutional, the Ohio Supreme Court commuted Cotten's sentence to life imprisonment.Cotten filed a complaint for a writ of habeas corpus in the Third District Court of Appeals in July 2023, arguing that his conviction and life sentence were invalid because they were based on an unconstitutional statute. The warden moved to dismiss the complaint, asserting that Cotten's life sentence had not expired and that the sentencing court had jurisdiction. The court of appeals granted the motion to dismiss, concluding that Cotten was imprisoned under a valid judgment from a court with proper jurisdiction and that his life sentence had not expired.The Supreme Court of Ohio reviewed the case and affirmed the court of appeals' dismissal. The court held that Cotten's life sentence was valid and that his arguments regarding the unconstitutionality of his original death sentence and the need for resentencing by a three-judge trial court were without merit. The court also denied Cotten's motion to strike documents attached to the warden's merit brief, which included a 2003 habeas corpus petition filed by Cotten that advanced similar arguments. The court concluded that Cotten's claims were not cognizable in habeas corpus and that the sentencing errors he alleged were not jurisdictional. View "Cotten v. Frederick" on Justia Law

Ronald Goldschmidt appealed the dismissal of his prohibition claim against Judge Alan Triggs and Magistrate Thomas Beridon of the Hamilton County Court of Common Pleas. Goldschmidt argued that Magistrate Beridon exceeded his authority by issuing a magistrate’s order instead of a magistrate’s decision regarding a charging order. This charging order was related to a civil action where Goldschmidt was found liable for over $1.5 million, and Elm Investment sought to collect on this judgment through Goldschmidt’s membership interests in several limited-liability companies.The First District Court of Appeals dismissed Goldschmidt’s claim, holding that the trial court had jurisdiction to issue the charging order and that any error in how it was issued was a matter of the exercise of jurisdiction, not a lack of it. The court also found that Goldschmidt had an adequate remedy in the ordinary course of law by filing a motion to set aside the magistrate’s order.The Supreme Court of Ohio reviewed the case de novo and affirmed the First District’s judgment. The court held that the issuance of the charging order as a magistrate’s order did not exceed the trial court’s subject-matter jurisdiction. It noted that procedural errors by a magistrate do not affect the trial court’s jurisdiction and render decisions voidable, not void. The court concluded that Goldschmidt had an adequate remedy in the ordinary course of law through a motion to set aside the magistrate’s order and an appeal from any subsequent ruling on such a motion. Therefore, the court affirmed the dismissal of Goldschmidt’s complaint for a writ of prohibition. View "State ex rel. Goldschmidt v. Triggs" on Justia Law

Moraine Wind, L.L.C. and other out-of-state wind farms applied to the Public Utilities Commission of Ohio (PUCO) for certification as eligible Ohio renewable-energy-resource-generating facilities. Carbon Solutions Group, L.L.C. (CSG), whose clients include Ohio-based renewable-energy suppliers, opposed the applications. PUCO approved the applications in September 2023. CSG filed an application for rehearing, which PUCO purported to grant for the limited purpose of further consideration, effectively extending the statutory deadline for a decision.CSG appealed PUCO's decision to the Supreme Court of Ohio, arguing that PUCO's failure to grant or deny the rehearing application within 30 days resulted in a denial by operation of law, as per R.C. 4903.10. PUCO moved to dismiss the appeal, claiming the court lacked jurisdiction because the rehearing application was still pending.The Supreme Court of Ohio held that PUCO's order granting rehearing for further consideration did not constitute a substantive grant of rehearing. The court emphasized that R.C. 4903.10 requires PUCO to grant or deny an application for rehearing within 30 days, and failure to do so results in a denial by operation of law. The court found that PUCO's practice of extending the deadline was not supported by statute and undermined the legislative intent for timely judicial review. Consequently, the court denied PUCO's motion to dismiss, affirming that CSG's application for rehearing was denied by operation of law, and the appeal was timely filed. View "In re Application of Moraine Wind, L.L.C." on Justia Law

The administrator of a deceased woman’s estate filed a complaint alleging medical malpractice and wrongful death against a doctor, the doctor’s employer, a hospital, and Medicare. The doctor and his employer included the affirmative defenses of insufficiency of process and insufficiency of service of process in their answer. Over two years later, they moved for summary judgment, arguing that the case had not commenced timely because the doctor had not been served with the complaint. The administrator opposed, claiming the doctor waived his defense by participating in the litigation. The trial court granted summary judgment, and the First District Court of Appeals affirmed.The administrator appealed to the Supreme Court of Ohio, urging it to overrule its decision in Gliozzo v. Univ. Urologists of Cleveland, Inc., which held that active participation in litigation does not waive the defense of insufficiency of service of process if properly raised and preserved. The Supreme Court of Ohio declined to overrule Gliozzo, reaffirming that the defense is not waived by participation in litigation if it is properly raised and preserved. The court emphasized that the burden of perfecting service lies with the plaintiff and that the rules of civil procedure govern the conduct of all parties equally.The Supreme Court of Ohio held that Dr. Ahmad properly preserved his insufficiency-of-service-of-process defense and that the administrator never perfected service of the complaint on him. Consequently, the trial court correctly dismissed the claims against Dr. Ahmad and his employer. The judgment of the First District Court of Appeals was affirmed. View "Ackman v. Mercy Health W. Hosp., Inc." on Justia Law