Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the court of appeals concluding that the federal Clean Air Act, 42 U.S.C. 7401 et seq., did not preempt the State's in-use motor vehicle emission control system tampering claims against Volkswagen, holding that the Clean Air Act did not preempt Ohio law and preclude an anti-tampering claim under Ohio's Air Pollution Control Act, Ohio Rev. Code 3704.01 et seq.After the United States Environmental Protection Agency discovered Volkswagen's scheme to enable its vehicles to perform better than they otherwise would have on federal emissions tests, the State of Ohio sued Volkswagen for its vehicle-emissions tampering, alleging that Volkswagen's conduct violated Ohio's Air Pollution Control Act. The trial court granted Volkswagen's motion to dismiss, concluding that Ohio's anti-tampering statute was preempted by the federal Clean Air Act. The court of appeals reversed. The Supreme Court affirmed, holding that the federal Clean Air Act neither expressly nor impliedly preempts section 3704.16(C)(3) or precludes an anti-tampering claim under the state Air Pollution Control Act for a manufacturer's post-sale tampering with a vehicle's emissions-control system. View "State ex rel. Yost v. Volkswagen Aktiengesellschaf" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against Keith Foley, warden of the Grafton Correctional Institution, holding that the information was insufficient to satisfy Ohio Rev. Code 2969.25(A).Appellant was indicted in two separate indictments on multiple counts of kidnapping and gross sexual imposition. The court dismissed the first indictment, after which Appellant pleaded guilty to five counts of gross sexual imposition. Appellant later filed a petition for a writ of habeas corpus alleging that the State was required to seek a new indictment before Appellant could be tried. The court of appeals dismissed the action because Def Appellant endant had failed to attach a proper affidavit describing his prior civil actions, as required by section 2969.25(A). The Supreme Court affirmed, holding that Appellant's failure to identify certain information in his affidavit required dismissal of his complaint. View "State ex rel. Steele v. Foley" on Justia Law

The Supreme Court reversed the judgment of the court of appeals upholding the order of the municipal court granting Defendant's motion to suppress, holding that the police officer's investigatory stop of Defendant was reasonable and thus did not violate the Fourth Amendment.At issue was whether the officer had reasonable suspicion to briefly detain Defendant in order to confirm or dispel an unidentified witness's claim that Defendant was operating a motor vehicle while intoxicated. The trial court granted Defendant's motion to suppress. The court of appeals affirmed, holding that the officer lacked the reasonable suspicion necessary to effectuate a lawful investigatory stop because the anonymous tip lacked sufficient indicia of reliability and because there was no evidence of erratic driving by Defendant prior to the stop. The Supreme Court reversed, holding that the officer had reasonable suspicion to investigate whether Defendant was driving while drunk based on the unidentified customer's tip and the officer's own partial corroboration of that tip. View "State v. Tidwell" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying writs of mandamus to compel appellees - the Cuyahoga County Prosecutor's Office and the City of North Olmsted - to prosecute crimes allegedly committed by Appellant's parents when Appellant was a minor, holding that the court of appeals did not err in denying Appellant's requested relief in mandamus.When Appellant was twenty-five years old, Appellant filed two charging affidavits alleging that his father committed felonious assault and felony domestic abuse and that his mother committed felony child endangering when Appellant was a minor. The prosecutor declined to prosecute or issue an arrest warrant. Appellant then commenced this action. The court of appeals granted the prosecutor's motion for summary judgment and denied the requested writ of mandamus. The Supreme Court affirmed, holding that the court of appeals did not err in denying Appellant's requested relief in mandamus. View "State ex rel. A.N. v. Cuyahoga County Prosecutor's Office" on Justia Law

The Supreme Court dismissed this action seeking a writ of procedendo ordering Judge Thomas J. Pokorny to rule on Relator's motions to dismiss counterclaims in consolidated cases pending in the court of common pleas, holding that the case was moot.Relator brought four actions against the Portage County Solid Waste Management District and the Portage County Board of Commissioners alleging violations of the Open Meetings Act, Ohio Rev. Code 121.22, related to the public business of the district conducted by the board. The district and the board filed amended counterclaims, and Relator filed motions to dismiss the counterclaims. Because Judge Pokorny already denied the motions for which Relator sought to compel a ruling in procedendo, the Supreme Court dismissed this action as moot. View "State ex rel. Ames v. Pokorny" on Justia Law

The Supreme Court held that a resolution passed by the Madison Local School District Board of Education to authorize certain school district employees to carry a deadly weapon or dangerous ordnance on school property "for the welfare and safety of [its] students" did not comply with Ohio law.At issue was whether the training or experience that Ohio Rev. Code 109.78(D) required of a school employee, other than a security guard or special police officer, in which the employee goes armed while on duty, applied to teachers, administrators, and other school staff whom a board of education had authorized to carry a deadly weapon in a school safety zone. The trial court concluded that the training-or-experience requirement did not apply to teachers, administrators, and most other school employees. The court of appeals reversed, holding that the resolution violated section 109.78(D) to the extent it permitted school employees without the statutorily-required training or experience to carry a deadly weapon while on duty. The Supreme Court affirmed, holding that the resolution violated section 109.78(D). View "Gabbard v. Madison Local School District Board of Education" on Justia Law