Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgments of the court of appeals vacating Defendants' sentences for involuntary manslaughter for the death of their adopted daughter, holding that the court of appeals did not have the authority to review the trial court's findings.Defendants were convicted of involuntary manslaughter and sentenced to ten years in prison. The court of appeals vacated the sentences and remanded the cases for resentencing. The Supreme Court reversed, holding (1) the court of appeals erred in holding that Ohio Rev. Code 2953.08(G)(2) permits an appellate court to review whether the record supports findings under Ohio Rev. Code 2929.11 and 2929.12; and (2) the judgment of the court of appeals vacating Defendants' sentences was not justified under section 2953.08(G)(2). View "State v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's App.R. 26(B) application for reopening, holding that the court of appeals applied the correct standard when it considered the application.On appeal, Appellant asked that the Supreme Court revisit the standard that Ohio courts of appeals must apply when considering applications for reopening. The Supreme Court declined to do so and (1) reaffirmed that the two-pronged standard set forth in Strickland v. Washington, 466 U.S. 668 (1984), which the Supreme Court adopted in State v. Reed, 660 N.E.2d 456 (1996), applies to applications for reopening under App.R. 26(B); (2) reaffirmed that courts of appeals should grant an application for reopening of the defendant shows a genuine issue was to whether she has a colorable claim that her appellate counsel's performance was deficient and that the deficient performance caused her prejudice; and (3) held that the court of appeals applied the correct standard in this case. View "State v. Simpson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the trial court terminating Defendant's community control and sentencing him to a two-year term of incarceration, holding that the trial court lacked the authority to conduct these community-control-revocation proceedings.On June 5, 2017, Defendant's community control sentence was due to expire. On September 12, 2018, the trial court revoked Defendant's community control and ordered him to serve a two-year prison term. The court of appeals reversed, holding that the trial court did not have the authority to conduct the revocation proceedings because notice of the violations and commencement of the proceedings did not occur before the expiration of Defendant's community control term. The Supreme Court affirmed, holding that the trial court lacked the authority to revoke Defendant's community control and sentence him to a term of imprisonment because the revocation proceedings were not commenced before the expiration of Defendant's community control term. View "State v. Rue" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the trial court's decision granting summary judgment for John Chervenak, trustee of the Chervenak Family Trust, and declaring the trust the owner of the disputed mineral rights in this case, holding that the Chervenaks satisfied the notice requirements of the Ohio Dormant Mineral Act.Timothy Gerrity filed this action to quiet title and for a declaratory judgment, claiming that he was the rightful owner of severed mineral rights under the Chervenak property. At issue was whether the Chervenaks satisfied the notice requirements that the Ohio Dormant Mineral Act, Ohio Rev. Code 5301.56(E)(1), imposes as prerequisites to deeming a severed mineral interest abandoned and vested in the owner of the land subject to the mineral interest. The lower courts rendered judgment for Chervenak. The Supreme Court affirmed, holding (1) application of the Dormant Mineral Act is not limited to circumstances in which every holder of a severed mineral interest has been identified; and (2) a surface owner must use reasonable diligence to identify and locate holders of a severed mineral interest, but what constitutes reasonable diligence will vary based on the facts of each case. View "Gerrity v. Chervenak" on Justia Law

The Supreme Court affirmed Defendant's convictions of aggravated murder and other crimes but vacated his death sentence, holding that the aggravating circumstances that Defendant was found guilty of committing did not outweigh the mitigating factors present in the case beyond a reasonable doubt, and therefore a sentence of death was not appropriate.Defendant was found guilty of multiple offenses, including aggravated murder and three accompanying death-penalty specifications - committing the aggravated murder during an aggravated robbery, an aggravated burglary, and a kidnapping. The trial court sentenced Defendant to death. At issue before the Supreme Court was whether the felony-murder aggravating circumstances that were found by the jury outweighed the mitigating factors presented by the defense beyond a reasonable doubt. The Supreme Court held that they did not and therefore remanded the case to the trial court for resentencing consistent with Ohio Rev. Code 2929.06. View "State v. Graham" on Justia Law

The Supreme Court affirmed Defendant's convictions for kidnapping, rape, and murder, holding that when a criminal defendant validly exercises his right to self-representation he can no longer raise claim under the Sixth Amendment to the United States Constitution that his trial counsel - standby or otherwise - was ineffective.In his criminal trial, Defendant waived his right to counsel under the Sixth Amendment and chose to represent himself. The trial court accepted Defendant's waiver and appointed standby counsel to be available to assist Defendant. On appeal, Defendant argued that the trial court violated his Sixth Amendment rights by limiting the role of his standby counsel. The court of appeals affirmed, holding that, based on the court's understanding of the typical role of standby counsel, the trial court did not improperly limit the role of standby counsel. The Supreme Court affirmed, holding that because the trial court had the discretion not to appoint standby counsel at all, the court did not abuse its discretion by appointing standby counsel with a limited role. View "State v. Hackett" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's conviction for engaging in a pattern of corrupt activity, in violation of Ohio Rev. Code 2923.32, holding that the State presented sufficient evidence to support Defendant's conviction.Defendant and two codefendants were each found guilty of engaging in a pattern of corrupt activity, possessing cocaine, illegally manufacturing drugs, and trafficking in cocaine. Defendant appealed, arguing that insufficient evidence supported his conviction for engaging in a pattern of corrupt activity. The court of appeals agreed and reversed the conviction. The Supreme Court reversed, holding that a reasonable juror could have found beyond a reasonable doubt that Defendant participated in incidents of illegal activity that were not isolated and established a pattern of corrupt activity. View "State v. Groce" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that Ohio Rev. Code 2107.24 eliminates the requirement of witness competency and that, therefore, the voiding provision of Ohio Rev. Code 2107.15 does not apply to essential witnesses to a remediated will, holding that the voiding provision of section 2107.15 applies equally to essential witnesses to both formally compliant and remediated wills.Zachary Norman, the son of Juley Norman, filed an application to probate a 2006 document claiming to be a will that was handwritten and signed by Joseph Shaffer. The will had no witness signatures. The probate court denied the application. On appeal, Zachary argued that Ohio Rev. Code 2107.24 does not require the witnesses to a noncompliant will to be "competent witnesses," and therefore, the voiding provision of section 2107.15 did not apply to a purported will that may be remediated pursuant to section 2107.24. The court of appeals agreed and reversed. The Supreme Court reversed, holding (1) section 2107.15 applies both to wills executed in compliance with section 2107.03 and those submitted pursuant to section 2107.24; and (2) the probate court correctly applied section 2107.15 and determined that Juley could not be included in the list of beneficiaries of Shaffer's estate. View "In re Estate of Shaffer" on Justia Law

In these consolidated appeals the Supreme Court reversed the judgments of the court of appeals, holding that the State presented sufficient evidence to support the convictions of Alvin Dent and William Walker (collectively, Defendants) for the felony offense of engaging in a pattern of corrupt activity under Ohio Rev. Code 2923.32.After a joint jury trial, Defendants were both found guilty of engaging in a pattern of corrupt activity, possessing cocaine, illegally manufacturing drugs, and trafficking in cocaine. The court of appeals reversed each of Defendants' convictions for engaging in a pattern of corrupt activity, holding that there was insufficient evidence to support those convictions. The Supreme Court reversed, holding that a reasonable juror could have found beyond a reasonable doubt that Defendants participated in incidents of illegal activity that were not isolated and established a pattern of corrupt activity. View "State v. Dent" on Justia Law

In this case involving the interplay between the Health Insurance Portability and accountability Act (HIPPA), the subsequent HIPPA Privacy Rule, and Ohio's common-law cause of action for the unauthorized, unprivileged disclosure by a medical provider to a third party of nonpublic medical information recognized in Biddle v. Warrant General Hospital, 715 N.E.2d 518 (Ohio 1999), the Supreme Court held that the patient in this case failed to state a claim under Biddle.Specifically, the Supreme Court held (1) HIPAA does not preclude a claim under Biddle when the limited disclosure of medical information was part of a court filing made to obtain a past-due payment on an account for medical services; (2) there is an exception to liability under Biddle when a medical provider makes a reasonable effort to limit the disclosure of the patient's medical information to the minimum amount necessary to file a complaint for the recovery of unpaid medical services charges; and (3) the medical provider in this case properly limited its closure of information to the minimum amount necessary to assert a cause of action to recover from the patient payment for unpaid medical bills. View "Menorah Park Center for Senior Living v. Rolston" on Justia Law