Justia Ohio Supreme Court Opinion Summaries

The Supreme Court granted Guernsey County Juvenile Court Judge David Bennett's motion to dismiss this habeas corpus action against him and sua sponte dismissed this action as to Muskingum County Juvenile Court Magistrate Erin Welch, holding that the petition was procedurally defective and failed to state a claim for relief.Petitioner filed an amended petition for a writ of habeas corpus on behalf of his minor son, E.G., naming Judge Bennett and Magistrate Welch as respondents and alleging that E.G.'s current detention was illegal. The Supreme Court dismissed the action because (1) the amended petition was defective for failure to satisfy Ohio Rev. Code 2725.04(D); (2) Petitioner failed to name a proper respondent; and (3) Petitioner's amended petition failed to stat a valid claim for habeas relief. View "Gomez v. Bennett" on Justia Law

The Supreme Court vacated the judgment of the court of appeals granting a limited writ of mandamus ordering the Industrial Commission of Ohio to identify the reasons for its denial of Employer's request for reconsideration of its order directing Employer to continue paying for Employee's drugs prescribed in connection with Employee's work injuries, holding that the Commission must reconsider Employee's motion in light of Ohio Adm.Code 4123-6-21.3.After Employer, which was self-insured for workers' compensation purposes, informed Employee that it would no longer reimburse Employee for his prescriptions in connection with his work-related injuries, Employee filed a motion asking the Commission to order Employer to continue paying for his drugs. The Commission granted the motion and denied Employer's request for reconsideration. Employer then sought a writ of mandamus directing the Commission to vacate its order and deny continued reimbursement for the prescriptions. The court of appeals granted a limited writ. The Supreme Court vacated the court of appeals' judgment and denied in part and granted in part the writ of mandamus, holding that the Commission should have considered Ohio Adm.Code 4123-6-21.3 in its determination of Employee's motion. View "State ex rel. T.S. Trim Industries, Inc. v. Industrial Commission of Ohio" on Justia Law

The Supreme Court denied a writ of mandamus sought to compel Respondents - the village of Bridgeport, the village's clerk and mayor, and the Belmont County Board of Elections - to certify to the elections board the sufficiency and validity of an initiative petition, holding that Relator failed to file the petition with the village clerk.This case involved a "Sensible Marihuana Ordinance" initiative petition in the village of Bridgeport. Ohio Rev. Code 731.28 requires the proponents of initiative petitions to file the completed petitions with the city auditor or village clerk. When Respondents refused to accept the petition, Relator filed this action. The Supreme Court denied the writ, holding that because Relator did not comply with the requirement in section 731.28 that he file the signed petition with the village clerk, Relator was not entitled to the writ. View "State ex rel. Schmitt v. Bridgeport" on Justia Law

The Supreme Court vacated Defendant's convictions of murder with capital specifications, aggravated burglary, kidnapping, and abuse of a corpse, holding that because the trial court accepted Defendant's guilty plea without first strictly complying with Crim.R. 11(C)(2)(c), Defendant's guilty plea was invalid.Specifically, the Supreme Court held that the trial court failed strictly to comply with the requirements for a valid plea colloquy under Crim.R. 11(C)(2)(c), and neither the prosecutor nor defense counsel brought the omitted constitutional rights to the court's attention at the time of the initial plea colloquy. Because this inattention was impermissible, especially in a case where a potential death sentence was at issue, the Supreme Court vacated Defendant's convictions and sentences and remanded the cause to the common pleas court for new proceedings. View "State v. Brinkman" on Justia Law

The Supreme Court reversed the decision of the Board of Tax Appeals (BTA) dismissing these appeals of final determinations of the tax commissioner on the grounds that they were untimely, holding that Am.Sub.H.B. No. 197 tolled the time limitation for filing the appeals, and Appellant filed the notices of appeal with both the tax commissioner and the BTA during the tolling period.On April 29, 2020, the tax commissioner journalized his final determinations upholding the tax assessments in each case. Service was completed by certified mail on May 4, 2020. Appellant delivered a notice of appeal to the tax department on June 26, 2020. The next day Appellant filed the notices of appeal with the BTA. The BTA dismissed both appeals as untimely. The Supreme Court reversed, holding that section 22(A)(1)(c) of H.B. 197 tolled Appellant's appeal period and that Appellant's appeals were timely filed. View "Chapman Enterprises, Inc. v. McClain" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals entering summary judgment in favor of Appellees - Portage County Board of Commissioners (Board), Portage County Solid Waste Management District Board of Commissioners (SWMD), and Portage County Court of Common Pleas, holding that the summary judgment is reversed as to the Board and the SWMD.Appellant claimed that the Board violated the Open Meetings Act, Ohio Rev. Code 121.22, and the Public Records Act, Ohio Rev. Code 149.43, by failing to conduct SWMD business in public meetings and by failing to prepare maintain, and produce accurate minutes of SWMD business. The Supreme Court held (1) the court of appeals erred in finding, as a matter of law, that the Board's use of a consent agenda in the manner described in the complaint did not violate the Open Meetings Act; (2) the court of appeals erred in granting summary judgment on Appellant's mandamus claim as it related to the minutes of certain SWMD meetings; and (3) Appellant's remaining allegations of error were without merit. View "State ex rel. Ames v. Portage County Board of Commissioners" on Justia Law

The Supreme Court reversed the judgment of the court of appeals to the extent it determined that an order of the domestic relations court had improperly modified a divorce decree and was void, holding that any error in the domestic relations court in exercising its jurisdiction in violation of Ohio Rev. Code 3105.171(I) rendered the order voidable, not void.Appellee moved to vacate an order adopted by the domestic relations court that set forth how his federal retirement benefits would be shared with Appellant, his former spouse, asserting that the order had improperly modified the divorce decree's division of marital property. The domestic relations court denied the motion to vacate. The court of appeals reversed in part, concluding that the domestic relations court lacked jurisdiction to modify the divorce decree. The Supreme Court reversed, holding that the court of appeals erred in determining that the order in this case was void because it modified the prior divorce decree. Rather, the error in the exercise of the court's subject-matter jurisdiction rendered the error voidable, not void ab initio. View "Ostanek v. Ostanek" on Justia Law

The Supreme Court affirmed the orders of the Public Utilities Commission requiring Allied Erecting & Dismantling Co., Inc. to pay for electricity consumed during a three-year period in which the Ohio Edison Company failed to bill Allied for one of its electric meters, holding that Allied failed to demonstrate reversible error.Ohio Edison estimated the amount owed based on Allied's historical electricity usage. The Commission determined that Ohio Edison provided sufficient evidence supporting the accuracy of its estimates and that Ohio Edison's estimated back bill was fair and reasonable. Allied appealed, challenging the Commission's orders on two grounds. The Supreme Court affirmed, holding that Allied failed to demonstrate that the Commission erred in deciding the complaint in Ohio Edison's favor. View "In re Complaint of Allied Erecting & Dismantling Co. v. Ohio Edison Co." on Justia Law

The Supreme Court affirmed Defendant's convictions of aggravated murder with an escaping-detection specification, kidnapping, felonious assault, possessing criminal tools, tampering with evidence, and having weapons while under a disability and Defendant's sentence of death, holding that there was no error in proceedings below.Specifically, the Supreme Court held (1) the State proved beyond a reasonable doubt that Defendant committed the offenses of aggravated murder and kidnapping; (2) the trial court did not deny Defendant's right to a fair trial by denying his motion for a new venire; (3) trial counsel did not provide ineffective assistance; (4) the trial court did not err in admitting evidence of other crimes, wrongs, or acts; (5) there was no error in the sentencing opinion; and (6) there was no other error in Defendant's sentencing. View "State v. Worley" on Justia Law

The Supreme Court affirmed the decision of the Board of Tax Appeals (BTA) affirming the decision of the tax commissioner denying Appellant's complaint challenging the continuing property tax exemption for a real estate parcel owned by the state and operated as the Ohio State University Airport (OSU Airport), the BTA's decision was reasonable and lawful.On appeal, Appellant argued that, given its use as of the tax lien date, the airport parcel did not qualify for exemption. Specifically, Appellant argued that either the entire airport should be taxed or that certain areas of the parcel should be split-listed as taxable. The Supreme Court affirmed BTA's decision continuing the exemption for the entire airport parcel, holding (1) Ohio Rev. Code 5715.271 placed the burden of proving entitled to continued exemption on OSU, and therefore, the BTA properly required OSU to bear that burden; (2) this Court lacked jurisdiction to grant relief to OSU on its evidentiary arguments; and (3) OSU proved that the airport was entitled to exemption under Ohio Rev. Code 3345.17. View "O'Keefe v. McClain" on Justia Law