Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus to compel the production of public records, holding that the court of appeals did not err.Appellant, an inmate, sent a public-records request to Julie Loomis, who provided some, but not all, of the requested records. Appellant filed an original action seeking to compel Loomis to make the remaining requested records available for his inspection. On remand, the court of appeals dismissed the complaint based on Appellant's failure to strictly comply with the mandatory requirements of Ohio Rev. Code 2969.25(A). The Supreme Court affirmed, holding (1) Appellant was required to comply with the requirements of section 2969.25(A); and (2) the court of appeals did not err by not converting Loomis's motion to dismiss into a motion for summary judgment. View "State ex rel. Bey v. Loomis" on Justia Law

The Supreme Court granted in part and denied in part the application of Charles Summers for court costs, attorney fees, and statutory damages following the Court's grant of a writ of mandamus ordering Respondents to produce documents to Summers, holding that Summers was entitled to an award of court costs.This case concerned Summers's request for public records relating to his son's criminal case. Summers sent the requests to Respondents - Mercer County Prosecuting Attorney Matthew Fox and Mercer County Sheriff Jeff Grey. When court-ordered mediation resulted in Summers receiving some, but not all, of the documents that he had requested the Supreme Court granted his writ of mandamus in part and denied it in part. Summers then filed his petition for an award of court costs, statutory damages, and attorney fees. The Supreme Court held (1) Summers was entitled to court costs; (2) Summers's status as the prevailing party in his mandamus action did not entitle him to an award of attorney fees, nor was he entitled to an award of bad-faith attorney fees; and (3) Summers was not entitled to an award of statutory damages. View "State ex rel. Summers v. Fox" on Justia Law

The Supreme Court granted Relators a writ of mandamus ordering the Trumbull County Board of Elections and its members (collectively, the Board) to remove the issue of Sandra Breymaier's recall from the June 1, 2021 special-election ballot, holding that the measure did not comply with ballot-access requirements.A group of Newton Falls electors presented to the clerk of the city council a petition to recall Breymaier, a city council member. The Mayor informed the Board that the Newton Falls city council had passed a motion to schedule a special election for June 1, 2021 on Breymaier's recall. The Board set the recall election to occur on June 1. Relators, including Breymaier, commenced this action seeking writs of prohibition and mandamus to prevent the Board from holding the recall election and ordering the Board to remove the recall measure from the June 1 ballot. The Supreme Court denied the writ of prohibition because the Board did not exercise quasi-judicial authority but granted a writ of mandamus because the city council had not duly passed a motion to set the recall election for June 1. View "State ex rel. Fritz v. Trumbull County Board of Elections" on Justia Law

The Supreme Court reversed the judgment of the court of appeals determining that the confirmation of an arbitration award had been issued prematurely, holding that although Ohio Rev. Code 2711.13 imposes a three-month deadline for motions to vacate, modify, or correct arbitration awards, that period is a maximum time that is not guaranteed.At issue was whether section 2711.13 requires a trial court to wait three months before confirming an arbitration award when the party opposing confirmation informs the trial court that it intends to file a motion to vacate, modify, or correct under section 2711.10 or 2711.11. The Supreme Court held that section 2711.13 does not operate as an automatic stay on confirmation of an arbitration award but, rather, requires parties opposed to the confirmation to be diligent in seeking to vacate, modify, or correct it. View "BST Ohio Corp. v. Wolgang" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's habeas corpus petition and denied all of Appellant's motions seeking various orders on appeal, holding that Appellant was not entitled to relief.Appellant was convicted of aggravated murder and other crimes and sentenced to life imprisonment without the possibility of parole. Appellant later filed a petition for a writ of habeas corpus alleging that the trial court committed numerous due process violations during his trial. The court of appeals dismissed the action. The Supreme Court affirmed and denied Appellant's motions, holding (1) Appellant's arguments did not state claims cognizable in habeas corpus; and (2) Appellant's motions were improper. View "Orr v. Schweitzer" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's habeas corpus complaint and, in a separate case, the court of appeals' order denying Appellant's motion to vacate the assessment of court costs against him, holding that the court of appeals did not err.Appellant, an inmate, filed a complaint for a writ of habeas corpus alleging that his original sentence was partially void due to an improper inclusion of a postrelease control sanction. The court of appeals dismissed the complaint, finding that Appellant failed to state any cognizable claim for relief in habeas corpus. After Appellant was sent notice of the court's judgment against him for the payment of court costs Appellant filed a document that the court of appeals treated as a motion to vacate court costs. The court of appeals denied the motion. The Supreme Court affirmed, holding (1) Appellant's claims were not cognizable in habeas corpus; and (2) the court of appeals properly denied Appellant's motion to vacate the judgment of court costs assessed against him. View "State ex rel. Davis v. Turner" on Justia Law