Justia Ohio Supreme Court Opinion Summaries

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

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