Justia Ohio Supreme Court Opinion Summaries

In this dispute between a coal mining company and the owner of a natural gas pipeline over whether the pipeline owner may recover for damage caused to the pipeline as a result of mining the Supreme Court reversed the judgment of the court of appeals and reinstated the judgment of the trial court in favor of the mining company, holding that surface damage liability waivers in the relevant property deeds were valid and enforceable.The mining company held its interest in the coal underneath the lands through property deeds that severed the surface estate from the mineral interest. The deeds included provisions waiving liability for damage to the land's surface caused by mining activities. The trial court entered judgment for the mining company. On appeal, the pipeline owner asserted that the surface damage liability waivers were rendered invalid by an administrative agency's regulation requiring mining operators to pay for damage to surface structures from mining activities. The court of appeals reversed. The Supreme Court reversed, holding (1) the administrative agency lacked authority to enact a regulation requiring mining operators to pay damages irrespective of common law property rights to the extent those rights have not been limited by federal law; and (2) the surface damage liability waivers at issue remained valid and enforceable. View "Columbia Gas Transmission, LLC v. Ohio Valley Coal Co." on Justia Law

The Supreme Court held that Ohio Rev. Code 2151.352 is unconstitutionally underinclusive as applied to indigent parents facing the loss of their parental rights in probate court and that indigent parents are entitled to counsel in adoption proceedings in probate court as a matter of equal protection of the law under the Fourteenth Amendment to the United States Constitution and Ohio Const. art. I, 2.Petitioners filed petitions in the probate court to adopt Mother's two children. Mother filed a request for appointed counsel, which the probate court denied. The court of appeals affirmed the denial of Mother's request for appointed counsel, concluding that equal protection and due process guarantees are inapplicable to requests for appointed counsel in adoption causes brought by private petitioners. The Supreme Court reversed, holding that the disparate treatment between indigent parents faced with losing parental rights in a custody proceeding in juvenile court, who are entitled to appointed counsel, and indigent parents faced with losing parental rights in an adoption proceeding in probate court, who are not entitled to appointed counsel, violates equal protection guarantees. View "In re Adoption of Y.E.F." on Justia Law

The Supreme Court held that, based on the plain language of Ohio Rev. Code 4511.33(A)(1), the definitions set forth in Ohio Rev. Code 4511.01 and the statutory scheme as a whole, the single solid white longitudinal line on the right-hand edge of a roadway - otherwise known as the fog line - does not prohibit "driving on" or "touching" the line.A highway patrol trooper stopped Defendant for failing to drive within the marked lanes, in violation of section 4511.33. Defendant was subsequently charged with a violation of section 4511.33 and of operating a vehicle while under the influence of alcohol. Defendant filed a motion to suppress, arguing that the trooper did not have probable cause or a reasonable and articulable suspicion to initiate the stop. The trial court granted the motion to suppress. The court of appeals reversed. The Supreme Court reversed, holding that because Defendant did not cross the fog line and driving on the fog line or touching it is not prohibited under section 4511.33(A)(1), no violation occurred. View "State v. Turner" on Justia Law

The Supreme Court held that a condition of community control imposed on Defendant that Defendant "make all reasonable efforts to avoid impregnating a woman" during his sentence was not reasonably related to the goals of community control, nor was it reasonably tailored to avoid impinging Defendant's liberty no more than necessary.Defendant was convicted of several felony counts of nonsupport of dependents. Defendant's sentence included the anti-procreation condition at issue. At issue before the Supreme Court was whether the anti-procreation prohibition impermissibly infringed upon Defendant's constitutional rights. The Supreme Court reversed, holding that the condition unnecessarily imagined upon Defendant's liberty, and therefore, the trial court must remove the anti-procreation condition but may impose other conditions that are appropriately tailored to the goals of community control. View "State v. Chapman" on Justia Law

The Supreme Court reversed the judgment of the court of appeals holding that entering a recreational travel trailer to commit theft does not constitute breaking and entering if the trailer is winterized, covered, and stored, holding that, contrary to the court of appeals' conclusion, such a structure is an "unoccupied structure" for the purposes of Ohio Rev. Code 2911.13(A).Defendant was convicted of breaking and entering under 2911.13(A). The court of appeals reversed, concluding that the trailer that Defendant broke into did not constitute an unoccupied structure for the purposes of the statute because it was not being "maintained" for residential use when the crime occurred. The Supreme Court reversed, holding (1) because the recreational travel trailer was manufactured for overnight accommodation, the fact that it was not occupied at the time of Defendant's theft rendered it an unoccupied structure rather than a nonstructure; and (2) therefore, the court of appeals erred in reversing Defendant's conviction and sentence based on insufficient evidence of the "unoccupied structure" element in section 2911.13(A). View "State v. Fazenbaker" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that Appellants - Ohioans for Concealed Carry, Inc. and Buckeye Firearms Foundation, Inc. - did not have standing to bring an action seeking declaratory and injunctive relief against Appellees - the City of Columbus and a Columbus City attorney (collectively, the City) - regarding two firearm-related ordinances that Appellants alleged were unlawful, holding that Appellants did not establish standing in this case.Appellants filed a complaint seeking an injunction against enforcement of the ordinances as unconstitutional, arguing that the ordinances are preempted by Ohio Rev. Code 9.68 and seeking a declaratory judgment that the ordinances violate section 9.68. The trial court found one ordinance to be unconstitutional and granted a permanent injunction enjoining its enforcement but denied injunctive relief regarding the other ordinance. The court of appeals reversed, concluding that Appellant failed to establish that they had standing under Ohio Rev. Code 733.59, Ohio Rev. Code 9.68, or Ohio Rev. Code Chapter 2721. The Supreme Court affirmed, holding that Appellants did not establish standing under section 9.68, section 733.58, or Chapter 2721 to challenge the ordinances. View "Ohioans for Concealed Carry, Inc. v. Columbus" on Justia Law

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