Justia Ohio Supreme Court Opinion Summaries

The Supreme Court denied the writ of mandamus sought by Relator, an inmate at the Toledo Correctional Institution (TCI), to compel Respondent, the public-records custodian, to provide the names of five inmates who were allegedly murdered at TCI between 2012 and 2014, holding that Relator failed to show that he had requested an existing record.Relator filed this original action seeking a writ of mandamus to compel Respondent to produce records in response to requests, alleging that a policy required the creation of incident reports concerning any murders that occur within a prison. The Supreme Court denied the writ, holding that Relator was not entitled to relief because requests that require the records custodian to create a new record by searching for selected information are improper requests under Ohio Rev. Code 149.43. View "State ex rel. Griffin v. Sehlmeyer" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition to vacate his murder conviction, holding that the court of appeals was correct to dismiss Appellant's claim.Appellant was convicted of murder in 2014. In 2020, Appellant filed a complaint for writs of mandamus and prohibition in the court of appeals against Judge Daniel Hogan, the now-retired judge who presided over his criminal case, alleging that his conviction must be vacated because Judge Hogan committed "fraud." The court of appeals dismissed the complaint. The Supreme Court affirmed, holding (1) the court of appeals correctly dismissed Appellant's complaint; and (2) Appellant's motion for judicial notice is denied. View "State ex rel. Jones v. Hogan" on Justia Law

The Supreme Court affirmed Defendant's sentences of death imposed in connection with his convictions of four counts of aggravated murder with multiple death specifications as to each count, holding that each of Defendant's four death sentences were appropriate and proportionate.After a trial, Defendant was found guilty of four counts of aggravated robbery and other crimes. Defendant was sentenced to death on all four counts of aggravated murder. The Supreme Court affirmed, holding (1) the trial court did not deny Defendant due process by not ordering a competency hearing sua sponte; (2) Defendant's claims that both his jury waiver and his subsequent guilty pleas were invalid because they were not knowing, voluntary, and intelligent were unavailing; (3) Defendant's trial court rendered constitutionally effective assistance; and (4) in sentencing Defendant, the court did not improperly weigh nonstatutory aggravating circumstances against him or improperly discount the mitigating factors. View "State v. Lawson" on Justia Law

The Supreme Court held that a provision found in just about every commercial and personal-property insurance policy issued in Ohio that bars coverage for damage caused by "water that backs up or overflows from a sewer" includes damage caused by sewage carried into an insured property by a backup or overflow event.Sewage from the local sewer system backed up into the Bank Nightclub, a bar that was insured at the time by United Specialty Insurance Company. The bar subsequently hired Cleantech to clean up the site and submitted a claim to its insurer. United Specialty denied the claim, citing an exclusion in the bar's policy for damage caused by water that backs up or overflows from a sewer. The bar assigned AKC any claims it might have against United Specialty, and AKC then brought this breach of contract claim. The trial court granted summary judgment in favor of United Specialty. The court of appeals reversed. The Supreme Court reversed, holding that the water-backup exclusion in the policy included damage caused by the sewage. View "AKC, Inc. v. United Specialty Insurance Co." on Justia Law

The Supreme Court vacated the judgment of the Tenth District Court of Appeals granting a writ of mandamus ordering the Industrial Commission of Ohio to vacate its order granting temporary total disability (TTD) compensation to Bridget Moss and then granted a limited writ, holding that the Commissioner must reconsider this case under the proper standard, as articulated in this opinion.Moss's employer, Ryan Alternative Staffing, Inc. (Ryan) sought a writ of mandamus ordering the Commission to vacate its order and deny TTD compensation because Moss had refused an offer of alternative employment within her medical restrictions. The Tenth District granted the writ. At issue on appeal was whether the Commission may award TTD compensation if an employee refuses an offer of alternative employment in good faith based on family circumstances. The Supreme Court vacated the Tenth district's judgment and granted a limited writ, holding that the Commission's orders exhibited confusion about the correct standard under which the employer's good faith standard was to be determined. View "State ex rel. Ryan Alternative Staffing, Inc. v. Moss" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's complaint seeking a writ of mandamus to compel the Cuyahoga County Court of Common Pleas to rule on Appellant's motion to reinstate bail and to set bail terms, holding that there was no error.Appellant was being held in the Cuyahoga County jail where he awaited trial on criminal charges in two cases. In Appellant's first criminal case, the trial court set bail at $5,000. Appellant posted ten percent of that amount and was released. In Appellant's second criminal case, the trial court set bail in the amount of $100,000 and revoked Appellant's bail in the first case based on his failure to appeal at a pretrial hearing. Appellant sought to have his bail reinstated, but the trial court denied relief. Appellant then filed a complaint for a writ of mandamus asking the court of appeals to issue an order compelling the trial court to rule on his motions and to set bail conditions that would allow for his pretrial release in his first case. The court of appeals denied relief. The Supreme Court affirmed, holding that Appellant's claim did not lie in mandamus. View "State ex rel. Wesley v. Cuyahoga County Court of Common Pleas" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing this appeal of a decision of the Ohio State Board of Education, holding that the state board's final determination that a charter school must repay approximately $60 million in excess funding could not be appealed under Ohio Rev. Code Chapter 119.In 2016, the Ohio Department of Education determined that the state had overpaid the Electronic Classroom of Tomorrow (ECOT), formerly Ohio's largest charter school, approximately $60 million based on a review of the school's enrollment data. ECOT appealed under Ohio Rev. Code 3314.08(K)(2)(b), which allows a charter school to appeal such a decision to the board of education for an informal hearing. The state board confirmed the department of education's determination. At issue was whether ECOT could appeal the board of education's "final" decision where section 3314.08(K)(2)(d) provides that any decision made by the board on such an appeal is final. The Supreme Court concluded that ECOT had no right to appeal the decision under Ohio Rev. Code Chapter 119. View "Electronic Classroom of Tomorrow v. State Board of Education" on Justia Law

The Supreme Court denied the writs of prohibition and mandamus sought by Relators to order Respondent, the Union County Board of Elections, to remove a zoning referendum from the November 2, 2021 general-election ballot, holding that Relators' arguments were unavailing.This case concerned the proposed rezoning of approximately 139 acres of property in Plain City, Union County, and Relators in this action owned the property, which was zoned rural residential. When the board of trustees voted to rezone the property to a planned-development district, a group of petitioners filed a referendum petition containing a summary of the zoning amendment. The board of elections certified the petition to be placed on the November 2 election ballot. Relators then filed a protest to the referendum petition, contending that it failed to satisfy the "brief summary" requirement of Ohio Rev. Code 519.12(H). The board voted to deny the protest and allow the referendum to appear on the ballot. The Supreme Court denied Relators' writs, holding that Relators did not show that the board abused its discretion or clearly disregarded applicable law in denying their protest. View "State ex rel. T-Bill Development Co. v. Union County Board of Elections" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction for possession of cocaine, holding the State did not prove beyond a reasonable doubt that Appellant committed the offense of possession of cocaine or any element of that offense within Seneca County.After Defendant gave birth to her son, J.B., he was tested for illegal substances and the test results showed the presence of cocaine metabolites in his urine and meconium. After a bench trial in the Seneca County Court of Common Pleas, Defendant was convicted of one count of possession of cocaine. The Supreme Court vacated Defendant's conviction of possession of cocaine, holding that the State failed to meet its burden of proving beyond a reasonable doubt that Defendant committed the offense in Seneca County. View "State v. Foreman" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court issuing a writ of mandamus to compel the City of Cincinnati to promote Jay Johnstone to the rank of captain, with backpay, holding that the trial court erred.Johnstone requested to be allowed to participate in a process to be promoted to the position of captain in the City's police department. After an examination, Johnstone was not promoted. Johnstone filed a petition seeking a writ of mandamus, which the trial court issued. The court of appeals affirmed. At issue before the Supreme Court was whether a municipal civil service commission may require that a police officer other than a patrol officer serve more than twelve months in the officer's current rank as a condition for being promoted to a higher rank. The Supreme Court reversed, holding that Ohio Rev. Code 124.44 does not allow a municipal civil service commission to require that a police officer other than a patrol officer serve more than twelve months in the officer's current rank as a condition for promotion. View "State ex rel. Johnstone v. Cincinnati" on Justia Law