Justia Ohio Supreme Court Opinion Summaries

In this second public-records action filed by Relators, Hogan Lovells U.S., LLP and Elizabeth Och, against Respondent, the Ohio Department of Rehabilitation and Correction (DRC), the Supreme Court denied Relators' request for a writ of mandamus requesting DRC's records relating to lethal injections, holding that Relators were not entitled to a writ of mandamus.In the first public-records case filed by Relators, the Supreme Court granted Relators' request for a writ of mandamus in part and ordered DRC to provide certain records relating to DRC's supply of drugs for its use in lethal injections. Although DRC provided more than 120 pages of documents, it asserted that two other documents at issue in this case were exempt from disclosure. Relators then brought this action seeking the withheld documents. The Supreme Court denied relief, holding that Relators were not entitled to a writ of mandamus concerning the requests but that, because DRC failed to timely respond to the request, Relators were entitled to an award of statutory damages in the amount of $500. View "State ex rel. Hogan Lovells U.S., LLP v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the decision of the Board of Tax Appeals (BTA) affirming the City of Cleveland's taxation of Hazel Willacy's stock-option income that she realized in 2016, holding that Willacy's propositions of law lacked merit.Willacy earned the disputed stock options in 2007 from her former employer while she was working in Cleveland. In 2009, Willacy retired and moved to Florida without having exercised any of the options. In 2014 and 2015, Willacy exercised the majority of the options and immediately resold the shares. In 2016, Willacy exercised the remaining options. Her former employer withheld her municipal-income-tax obligation and paid it to Cleveland. Willacy sought a refund on the grounds that she did not live or work in Cleveland. The refund was denied, and the BTA affirmed the denial. The Supreme Court affirmed, holding that Cleveland's taxation of Willacy's 2016 compensation was required under municipal law and did not violate her due process rights under either the United States or Ohio constitutions. View "Willacy v. Cleveland Board of Income Tax Review" on Justia Law

The Supreme Court held that Defendant, who pleaded no contest in 1987 to attempted murder after shooting a young man in the neck and was reindicted in 2016 for the aggravated murder of the same man after he died allegedly as a result of injuries from the shooting, may be prosecuted on the new murder charge.In 1987, Defendant pled no contest to attempted murder after shooting Danuell Jackson in the neck, leaving him paralyzed from the waist down. In 2014, Jackson died. The autospy examiner ruled the death a homicide because it was caused by infections attributed to Jackson's paraplegia. In 2016, the State indicted Defendant for the aggravated murder of Jackson. Defendant moved to dismiss the indictment, arguing that it violated the terms of a negotiated plea agreement Defendant claimed he entered into with the State in 1987. The State countered that there had not been a negotiated plea. The trial court granted Defendant's motion to dismiss. The court of appeals affirmed. The Supreme Court reversed, holding that because there was no evidence that Defendant's 1987 plea was the product of negotiations between the State and Defendant, the rule announced in State v. Carpenter, 623 N.E.2d 66 (Ohio 1993), did not prevent the State from prosecuting Defendant on the new murder charge. View "State v. Azeen" on Justia Law

The Supreme Court granted a writ of mandamus compelling Respondents, the Stark County Board of Commissioners and its members, to acquire new voting machines, holding that the Commissioners had a clear legal duty to acquire the machines under Ohio Rev. Stat. 3506.02(A).In 2018, the General Assembly passed Am.Sub.S.B. No. 135, providing funding to Ohio counties to subsidize the purchase of new voting machines. In 2020, the Stark County Board of Elections voted to acquire voting machines from Dominion Voting Systems. The Commissioners voted not to adopt the Board's recommendation. The elections board then filed this original action seeking a writ of mandamus to compel the Commissioners to acquire the new voting machines from Dominion. The Supreme Court granted the writ, holding that the Commissioners had a clear legal duty to acquire the equipment and that the elections board had a clear legal right to the acquisition. View "Stark County Board of Elections v. Stark County Board of Commissioners" on Justia Law

The Supreme Court affirmed the decision of a five-judge commission concluding that, while she was a judicial candidate in 2020, Karen Kopich Falter committed violations of Jud.Cond.R. 4.3(A), holding that Falter's objections to the commission's misconduct findings were overruled, and the commission did not abuse its discretion in issuing sanctions against Falter.Falter, an Ohio attorney, was publicly reprimanded by the commission and ordered to pay a $1,000 fine for committing violations of Jud.Cond.R. 4.3(A), which prohibits a judicial candidate from disseminating campaign material about an opponent either knowing that it is false or in reckless disregard of whether or not it is false. Falter appealed the commission's sanction. The Supreme Judicial Court affirmed, holding (1) Falter's objections to the sanction are overruled; and (2) the Commission did not abuse its discretion in sanctioning Falter for her violations of Jud.Cond.R. 4.3(A). View "In re Judicial Campaign Complaint Against Falter" on Justia Law

The Supreme Court affirmed the decision of the Board of Tax Appeals (BTA) upholding the tax commissioner's denial of a municipality's request for an exemption for tax years 2015, 2016, and 2017, holding that the BTA reasonably and lawfully upheld the denial of an exemption.The village of Obetz enacted an ordinance in 2017 in an effort to reinstate the tax-exempt status of real property under a tax-increment-financing (TIF) arrangement after it expired in 2014. The commissioner explained that the 2017 could not retroactively reinstate the exemption for tax years 2015, 2016, and 2017 because Ohio Rev. Code 5709.40(G) provides that an exemption may begin no earlier than a tax year that "commences after the effective date of the ordinance." The BTA affirmed, agreeing that the 2017 ordinance created a new exemption rather than extending the earlier one so that section 5708.40(G) barred the exemption from applying during the relevant tax years. The Supreme Court affirmed, holding that the BTA's decision was reasonable and lawful. View "Obetz v. McClain" on Justia Law

The Supreme Court granted a writ of mandamus ordering the Ohio Department of Education (ODE) to approve Relators' applications for Quality Community School Support (QCSS) grants and to pay them the amounts due under 2019 Am.Sub.H.B. No. 166 (H.B. 166), holding that Relators were entitled to the writ.Under the QCSS program, a community school that has met certain criteria would receive grant funding for the 2020-2021 and 2021-2011 fiscal years. Relators, twelve Horizon Science Academy community schools, had applied for QCSS grants, but ODE denied the applications, concluding that ODE was not "in good standing" as required by section 265.335 of H.B. 166. The ODE's determination was made on the grounds that the schools' operator was a foreign corporation not licensed with the Ohio secretary of state. The Supreme Court granted Relators' requested writ of mandamus, holding that ODE's interpretation of "in good standing" was incorrect. View "State ex rel. Horizon Science Academy of Lorain, Inc. v. Ohio Department of Education" on Justia Law

The Supreme Court affirmed the decision of the Board of Tax Appeals (BTA) affirming the journal entry issued by Ohio Tax Commissioner Jeffrey McClain adopting a per-acre valuation table for use by county auditors in assessing land that qualifies for "current agricultural use valuation" (CAUV), holding that substantial evidence supported the BTA's decision.For three reasons, the BTA found no abuse of discretion on the part of the tax commissioner in adopting the CAUV unit-value table. The Supreme Court affirmed, holding (1) Ohio Adm.Code 5703-25-34(E) furnished no basis for challenging the CAUV journal entry; and (2) the BTA correctly determined that the tax commissioner did not abuse his discretion in adopting the valuation table. View "Johnson v. McClain" 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 officials to transfer him from the Northeast Ohio Correctional Center (NEOCC) to the Franklin County jail, holding that the court of appeals did not err.The court of appeals dismissed Appellant's complaint in its entirety as moot, concluding that any transfer of Appellant from NEOCC to the Franklin County jail would have been a vain act. The Supreme Court affirmed, holding that granting the writ of mandamus Appellant sought to compel his transfer would do nothing more than require a vain act. View "State ex rel. Peoples v. O'Shaughnessy" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's action seeking a writ of prohibition to prevent the enforcement of a foreclosure judgment against her, holding that the court of appeals did not err.Appellant filed this prohibition action asserting that Wells Fargo Bank, N.A., which filed the foreclosure action against Appellant, had failed to obtain service within one year of filing the complaint. The court of appeals sua sponte dismissed the cause, concluding that this action was moot and that Appellant's appeal in the foreclosure action constituted an adequate remedy precluding extraordinary relief. The Supreme Court affirmed, holding (1) Appellant's cause of action was not moot; but (2) Appellant's opportunity to assert service and personal jurisdiction defenses in the foreclosure case and on appeal was an adequate remedy at law. View "Lundeen v. Turner" on Justia Law