Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals concluding that a child-abuse investigator employed by a county children-services agency need not give the warnings required by Miranda v. Arizona, 384 U.S. 436 (1966), before questioning a child suspected of committing child abuse, holding that the questioning in this case violated neither Miranda nor the suspect's federal due process rights.The trial court in this case granted the suspect's motion to suppress, finding that the suspect's statement to the agency had been obtained in violation of his due process rights. The court of appeals reversed. The Supreme Court affirmed, holding that where the evidence demonstrated that the child-abuse investigator who interviewed the suspect was neither a law enforcement officer nor acting under the direction or control of the police and where the suspect's confession was not causally related to any conduct of the police, the court of appeals correctly concluded that the confession resulting from the questioning was admissible at trial. View "In re M.H." on Justia Law

In this case involving the proper scope of the litigation privilege in Ohio the Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court granting judgment on the pleadings concluding that certain actions of the Certified Steel Stud Association's directors were protected by the litigation privilege, holding that judgment on the pleadings was inappropriate.ClarkDietrich previously sued the Association alleging that the Association made defamatory statements about ClarkDietrich's products. William Gardner and Edward Slish (together, Appellees) were members of the Association's board of directors at that time. The jury returned a verdict in favor of ClarkDietrich. John Reister, who was subsequently appointed as a receiver on behalf of the Association, filed this action claiming that Appellees breached their fiduciary duties by mishandling the ClarkDietrich litigation. The court of appeals affirmed, concluding that Appellees' actions were protected under the litigation privilege rule. The Supreme Court reversed, holding (1) the litigation privilege protects statements, not actions; and (2) the decision to grant judgment on the pleadings was improper in this case. View "Reister v. Gardner" on Justia Law

In this original action involving a dispute between two judges who sit on the Sandusky County Court the Supreme Court granted a peremptory writ of prohibition that vacated Judge John Kolesar's judgment entry vacating Judge Mary Elizabeth Fiser's judgment entries granting pay raises to certain personnel, holding that Judge Kolesar's vacating entry arose from an exercise of judicial power that he patently and unambiguously lacked jurisdiction to exercise.Shortly after Judge Fiser issued entries granting pay raises to court personnel Judge Kolesar, who serves as the court's administrative judge, issued a judgment entry vacating Judge Fiser's entries and forbidding pay raises and the expenditure of court resources that did not have his approval. Judge Fiser sought a writ of prohibition to prevent Judge Kolesar from enforcing his entry, and Judge Kolesar sought a writ of prohibition to prohibit Judge Fiser from making future entries that infringe on his powers as administrative judge. The Supreme Court granted a peremptory writ of prohibition that vacated Judge Kolesar's vacating entry, holding that Judge Kolesar patently and unambiguously lacked jurisdiction to issue his vacating entry. View "State ex rel. Fiser v. Kolesar" on Justia Law

The Supreme Court reversed the judgment of the court of appeals granting summary judgment for the State and denying Appellant's petition for a writ of mandamus to compel the State to initiate property-appropriation proceedings in this regulatory-takings case, holding that genuine issues of material fact remained regarding whether Appellant had suffered a total or partial taking.Appellant alleged that it had suffered a taking of its property when the Ohio Department of Natural Resources' Division of Oil and Gas Resources Management suspended Appellant's operation of one of its two saltwater-injection wells. The Division suspended the well's operation due to concerns that the well had induced two earthquakes in its vicinity. The court of appeals granted summary judgment for the State, determining that Appellant had suffered neither a total nor a partial governmental taking. The Supreme Court reversed, holding that genuine issues of material fact precluded summary judgment. View "State ex rel. AWMS Water Solutions, LLC v. Mertz" on Justia Law

The Supreme Court affirmed the order of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that Appellant failed to state a claim cognizable in habeas corpus.Appellant, an inmate at the Trumbull Correctional Institution, filed a petition for a writ of habeas corpus alleging that his transfer from juvenile court to adult court was void and that, therefore, his resulting convictions were also void. The court of appeals held that Appellant's conviction was barred by res judicata. Further, the court rejected Appellant's claim on the merits. The Supreme Court affirmed, holding that, based on this Court's decision in Smith v. May, 148 N.E.3d 542, Appellant failed to state a claim cognizable in habeas corpus. View "Steele v. Harris" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that the juvenile court lacked jurisdiction to adjudicate R.B. delinquent, holding that the timing requirements of Ohio Rev. Code 2152.84 are not jurisdictional.The juvenile court adjudicated R.B. delinquent, classified him as a sex offender, and imposed a disposition that included probation. After a second sex-offender-classification hearing the juvenile court kept R.B.'s classification the same. R.B. appealed, arguing that the juvenile court was required to hold the review hearing and and issue its decision on the precise day his disposition ended and because the juvenile court did not do so, it lost jurisdiction to continue his classification. The Supreme Court disagreed, holding (1) the language "upon completion of the disposition" found in section 2152.84(A)(1) requires only that the court's review take place within a "reasonable time" of the juvenile's completion of his disposition; and (2) section 2151.23(A)(15) vests the juvenile court with jurisdiction to carry out its requirements under the classification statutes, independent of whether the delinquent child has reached the age of twenty-one. View "In re R.B." on Justia Law

The Supreme Court held that there is no irreconcilable conflict between the general provisions of the Ohio Marketable Title Act, Ohio Rev. Code 5301.47 et seq., as applied to severed mineral interests, and the Ohio Dormant Mineral Act, Ohio Rev. Code 5301.56.Appellants claimed they were the owners of a portion of a severed royalty interest in oil and gas underlying about sixty-six acres of land in Monroe County. Appellees filed this action for a declaratory judgment that the Marketable Title Act had extinguished the severed royalty interest and had vested that previously severed interest in Appellees. Appellants argued that the Dormant Mineral Act supersedes and controls over the original Marketable Title Act due to a conflict between the two acts. The trial court declared Appellants the owners of a 1/16 royalty interest, holding that the Dormant Mineral Act irreconcilably conflicts with the general provisions of the Marketable Title Act and that the more specific Dormant Mineral Act controls. The court of appeals reversed. The Supreme Court affirmed, holding that there is no irreconcilable conflict between the two acts, and therefore, they are applied as independent, alternative statutory mechanisms that may be used to reunite severed mineral interests with the surface property subject to those interests. View "West v. Bode" on Justia Law

The Supreme Court denied Kimani Ware's request for a writ of mandamus to compel the production of records in response to his eight public-records requests, denied Ware's request for an in camera inspection of the records, and denied statutory damages, holding that Ware was not entitled to a writ of mandamus as to the public-records requests.Specifically, the Supreme Court held (1) Ware was not entitled to a writ of mandamus as to requested docket sheets and grand jury reports; (2) because the clerk's office offered to make the remaining public records requested by Ware available and identified the cost for copying them, Ware was not entitled to a writ of mandamus as to those public-records requests; (3) an inspection of the records was unnecessary, and therefore, Ware's request for an in camera inspection was unnecessary; and (4) Ware was not entitled to statutory damages. View "State ex rel. Ware v. Giavasis" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting the motion filed by Cuyahoga County Court of Common Pleas judge William T. McGinty to dismiss Appellants' action seeking a writ of prohibition to prevent McGinty from enforcing a discovery order, holding that a writ of prohibition was not the correct mechanism to challenge Judge McGinty's order.Kaylynn Counts, who allegedly assaulted Appellants, was awaiting trial before Judge McGinty when she filed a motion requesting an order allowing her to inspect and photograph Appellants' home to aid in "forensically recreating the incident" for her case. Judge McGinty granted the motion. Appellants then filed this action, arguing that Marsy's Law and the Fourth Amendment deprived Judge McGinty of the authority to issue the order permitting Counts and the defense team to have access to Appellants' residence. The court of appeals dismissed the prohibition action. The Supreme Court affirmed, holding that while crime victims have a right under the Ohio Constitution to judicial review of discovery orders affecting their Marcy's Law rights, a writ of prohibition was not the appropriate remedy to challenge Judge McGinty's discovery order, and moreover, Appellants had an adequate remedy in the ordinary course of law by way of an appeal. View "State ex rel. Thomas v. McGinty" on Justia Law

The Supreme Court reversed the orders of the Public Utilities Commission finding that intervening appellee Ohio Edison Company's 2017 earnings were not significantly excessive, holding that the Commission's decision to exclude revenue resulting from Ohio Edison's Distribution Modernization Rider (DMR) from the earnings test was not reasonable.Electric distribution utilities that opt of provide service under an electric security plan must undergo an annual earnings review by Commission. If the Commission finds that the plan resulted in significantly excessive earnings compared to similar companies, the utility must return the excess to its customers. The Office of the Ohio Consumers' Counsel appealed from the Commission's orders finding that Edison's 2017 earnings were not significantly excessive. The Supreme Court reversed, holding that the Commission's exclusion from the earnings test revenue resulting from the DMR, which was approved as part of Edison's electric security plan, was not reasonable. View "In re Determination of Existence of Significantly Excessive Earnings for 2017 Under the Electric Security Plan of Ohio Edison Co." on Justia Law