Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the decision of the court of appeals concluding that statements made by a medical doctor during a medical board investigation were inadmissible in a subsequent criminal prosecution of that doctor, holding that the trial court properly admitted incriminating answers given by the doctor during the investigation.Specifically, the Supreme Court held (1) a medical license is a property right, and the threatened loss of the license is a form of coercion that can compromise the defendant's Fifth Amendment privilege against self-incrimination; (2) in order for coercion to be sufficient to warrant the suppression of statements made during a medical board investigative review, the coercion must be both subjectively believed and objectively reasonable; and (3) competent, credible evidence supported the trial court's factual finding that the doctor did not objectively believe that a refusal truthfully to answer questions posed by the medical board investigator could lead to the loss of the doctor's medical license. View "State v. Gideon" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the trial court's judgment concluding that Green Thumb did not violate Ohio's Deceptive Trade Practices Act, holding that Wooster Floral & Gifts, LLC failed to demonstrate that Green Thumb Floral & Garden Center, Inc.'s use of the domain name www.woosterfloral.com caused a likelihood of confusion as to the source of goods sold on the website.Green Thumb owned the domain name www.woosterfloral.com. Wooster Floral & Gifts, a competing flower shop, brought this lawsuit under the Deceptive Trade Practices Act seeking to block Green Thumb from using the address. The trial court ruled in favor of Green Thumb, finding that Green Thumb's use of the domain name was unlikely to cause confusion as to the source of goods or services because the home page was clearly identified as "Green Thumb Floral" and there was no use of the trade name "Wooster Floral" within the website. The court of appeals affirmed. The Supreme Court affirmed, holding that, under both federal precedent and the plain terms of the Ohio statute, a consumer landing on Green Thumb's website was unlikely to be confused about the entity that would be fulfilling the consumer's order. View "Wooster Floral & Gifts, LLC v. Green Thumb Floral & Garden Center, Inc." on Justia Law

The Supreme Court affirmed the judgment of the court of appeals vacating certain sexually-violent-predator specifications that had been applied to Defendant's sentence, holding that, as applied, the specifications violated the Ex Post Facto Clause of the United States Constitution.Defendant was found guilty of numerous counts of rape, kidnapping, and related crimes involving three victims, including sexually-violent-predator specifications. The court of appeals upheld the convictions on all assignments of error except those challenging Defendant's convictions on the sexually-violent-predator specifications that attached to the crimes that Defendant committed before April 29, 2005. The court vacated the convictions on those specifications as violating the Ex Post Facto Clause. The Supreme Court affirmed, holding that the application of the current version of Ohio Rev. Code 2971.01(H)(1) to Defendant for his crimes in 2003 and 2005 violated the Ex Post Facto Clause. View "State v. Townsend" on Justia Law

The Supreme Court granted in part and denied in part a writ of mandamus sought by Charles Summers to compel the production of public records by Mercer County Prosecuting Attorney Matthew Fox and Mercer County Sheriff Jeff Grey, holding that Summers was entitled to a writ of mandamus as to certain requests.Summers pleaded guilty to several counts of sexual battery in violation of Ohio Rev. Code 2907.03. In his public-records request to Mercer County Prosecutor's Office Summers requested several items relating to his criminal prosecution. Summers then requested from the Mercer County Sheriff several other items related to his criminal case. The county denied Summers's requests. Summers then commenced this action. The Supreme Court granted a writ in part, holding that Summers demonstrated by clear and convincing evidence that he had a clear legal right to some of the requested relief, and the county had a clear legal duty to provide that relief. View "State ex rel. Summers v. Fox" on Justia Law

The Supreme Court affirmed Defendant's two aggravated murder convictions and death sentences, holding that no reversible error occurred in the proceedings below.Specifically, the Supreme Court held (1) defense counsel were not ineffective for failing to request a change of venue or in filing a joint motion for a gag order; (2) defense counsel were not ineffective for withdrawing Defendant's plea of not guilty by reason of insanity in Defendant's absence or in failing to request a continuance to obtain additional neuroimaging; (3) defense counsel were deficient for failing to object to certain evidence, but the deficient performance did not result in prejudice; (4) defense counsel made an inappropriate comment during mitigation-phase closing argument, but the comment did not prejudice Defendant; (5) Defendant's remaining ineffective assistance of counsel claims were without merit; (6) the trial court did not err in replacing one juror with an alternate juror; and (7) Defendant's sentences were not unlawful. View "State v. Grate" on Justia Law

The Supreme Court reversed the decision of the Public Utilities Commission of Ohio (PUCO) dismissing a complaint against a company that provided submetering services on the grounds that it did not have jurisdiction over the claims, holding that PUCO inappropriately applied a jurisdictional test of its own making.The PUCO's jurisdiction is provided by statute, and the PUCO generally has jurisdiction over any business that is a public utility. In dismissing the complaint in this case, the PUCO did not look to the statutory scheme to determine whether Nationwide Energy Partners, LLC, the submeterer, was a public utility. Instead, the PUCO used a test set forth in a 1992 PUCO order and recently modified by the PUCO to determine the extent of its jurisdiction. The Supreme Court reversed, holding (1) the PUCO's jurisdiction is established by statute, not an agency-created test; and (2) therefore, this case is remanded for the PUCO to determine whether it has jurisdiction based upon the jurisdictional statute. View "Wingo v. Nationwide Energy Partners, LLC" on Justia Law

The Supreme Court granted a writ of mandamus sought by Omni Energy Group, LLC as to the Ohio Department of Natural Resources, Division of Oil and Gas Resources Management chief Eric Vendel ordering him to rule upon the validity of objections that were submitted concerning Omni's two saltwater injection well permit applications, holding that Omni was entitled to the writ.When the division chief did not render a decision on Omni's applications Omni filed a complaint against the division, Vendel, and department director Mary Mertz, sought a writ of mandamus compelling them to either issue or deny the permits. The Supreme Court granted a writ of mandamus, but instead of ordering Vendel immediately to render a decision on the applications, the Court ordered him to rule upon the validity of objections as required under Ohio Adm.Code 1501:9-3-06(H)(2)(c), holding (1) Omni had a clear legal right to, and Vendel had a clear legal duty to provide, a ruling on the validity of objections submitted against the applications; and (2) Omni did not suggest a basis for granting a writ of mandamus as to the division or to Mertz. View "State ex rel. Omni Energy Group, LLC v. Ohio Department of Natural Resources, Division of Oil & Gas Resources Management" on Justia Law

The Supreme Court answered questions certified by the court of appeals in the negative and affirmed the judgment of the court of appeals reversing the trial court's grant of summary judgment to Akron General Medical Center (AGMC) on the issue of whether AGMC was liable for a cause of action for negligent hiring, retention, or supervision, holding that the grant of summary judgment was inappropriate.Malieka Evans filed a complaint alleging that she had been sexually abused and assaulted by Dr. Amir Shahideh, one of AGMC's employees, while seeking treatment at AGMC. The trial court granted summary judgment for AGMC based on Evans's failure to have filed a cause of action against Dr. Shahideh and her inability to establish the doctor's civil liability or criminal guilt. The court of appeals reversed and certified to the Supreme Court two questions of law. The Supreme Court held (1) a plaintiff need not show that an employee has been adjudicated civilly liable or has been found guilty of a crime in order for the plaintiff to maintain a negligent hiring, retention, or supervision claim against an employer; (2) the statute of limitations for such a claim is not affected by the statute of limitations governing the underlying legally wrongful conduct of the employee; and (3) summary judgment was improper. View "Evans v. Akron General Medical Center" on Justia Law

The Supreme Court denied the petition for a writ of mandamus filed by the South Euclid Municipal Court asking the Supreme Court to compel the City of South Euclid to comply with a funding order issued by the municipal court judge, holding that the judge was not entitled to mandamus relief.The judge in this case requested that the City allocate thirty percent more money than allocated for the previous year for the municipal court's 2019 budget. The court then issued a funding order directing the city council to allocate the full requested amount. The city council did not give the court the full amount. The municipal court subsequently filed a complaint for a writ of mandamus seeking to compel the city to comply with the judge's funding order. The Supreme Court denied the writ, holding that the municipal court failed to establish its entitlement to a writ. View "State ex rel. Williams-Byers v. City of South Euclid" on Justia Law

The Supreme Court reversed the judgment of the court of appeals denying Appellant's request for a writ of mandamus ordering the City of Cincinnati to repair and maintain two streets located within the City's boundaries, holding that the court of appeals' analysis eschewed a comprehensive mandamus discussion.Appellant sought a writ of mandamus to compel the City to repair and maintain the streets at issue, alleging that the City's neglect of the streets had resulted in unsafe conditions caused by inadequate water drainage. The court of appeals denied the writ, concluding that the streets had never become public through either a statutory or a common-law dedication. The Supreme Court reversed, holding (1) the Platting Commission Act furnishes a means of achieving a statutory dedication; (2) the two streets at issue were the subject of a statutory dedication as of 1876; and (3) because the parties did not adequately brief the clear-legal-right and clear-legal-duty requirements of the mandamus standard, the cause is remanded for full application of the mandamus standard. View "State ex rel. Delta Lookout, LLC v. City of Cincinnati" on Justia Law