Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals denying the request brought by Manor Care, Inc., a self-insured employer, for a writ of mandamus ordering the Bureau of Workers' Compensation to reimburse it for lump-sum permanent-total-disability (PTD) compensation payments, holding that Manor Care did not establish a clear legal right to relief.Manor Care made lump-sum payments under protest to two injured workers in order to correct its long-term underpayment of their permanent-total-disability (PTD) compensation. Manor Care then requested reimbursement from the Disabled Workers' Relief Fund, contending that Manor Care's underpayment of PTD compensation should be offset by the Bureau's corresponding overpayment of relief-fund benefits to the same employees, for which Manor Care had reimbursed the Bureau as part of its annual assessments. The Bureau denied the request. Manor Care then filed this action alleging that the Bureau abused its discretion by requiring Manor Care to, in effect, double-pay the purported PTD underpayment to the employees and refusing to reimburse Manor Care for the PTD underpayment amount. The court of appeals denied the writ. The Supreme Court affirmed, holding that Manor Care identified no authority granting a clear legal right to the relief it sought. View "State ex rel. Manor Care, Inc. v. Bureau of Workers' Compensation" on Justia Law

The Supreme Court affirmed the decision of the court of appeals granting the motion for judgment on the pleadings filed by the City of Warren on this complaint asserting that state civil service statutes prohibit abolishment of upper-rank police positions by attrition, holding that Ohio Rev. Code 124.37 and 124.44 do not prohibit upper-rank positions from being abolished by attrition.Members of bargaining units represented by Ohio Patrolmen's Benevolent Association sought a writ of mandamus ordering that the officers be promoted pursuant to state civil-service law. The City declined to offer the officers promotions or exams because the City had passed an authorized-strength ordinance to abolish the subject positions upon the retirement of their former occupants. The officers argued in their complaint that the City must first promote the individual officers and only then would the City have the power to abolish the positions at issue. The court of appeals granted the City's motion for judgment on the pleadings and dismissed the petition. The Supreme Court affirmed, holding that a City, without violating sections 124.44 and 124.39 enact an ordinance to reduce a police force by prospectively canceling the legal authorization for certain positions upon the retirement of the incumbents. View "State ex rel. Ohio Patrolmen's Benevolent Ass'n v. Warren" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the court of claims ordering, subject to certain redactions, the public release of a video from an exterior courthouse security camera that captured the shooting of a judge, holding that the video was not exempt from release as a public record.The court of claims determined that competent evidence had not been presented to establish that the video was a "security record" under Ohio Rev. Code 149.433(A)(1) and was therefore exempt from release. The court of appeals reversed, concluding that the video was a security record that was exempt from public disclosure. The Supreme Court reversed, holding that the surveillance video did not fall squarely within the security-record exemption. View "Welsh-Huggins v. Jefferson County Prosecutor's Office" on Justia Law

The Supreme Court reversed the judgment of the court of appeals upholding Defendant's convictions in a second appeal, holding that Defendant's right to a speedy trial was violated after his case was remanded to the trial court for retrial.The trial court convicted Defendant of two counts of aggravated robbery and one count of failure to comply with an order or signal of a police officer. The court of appeals reversed and remanded the matter. On remand, Defendant pleaded no contest to the charges of having a weapon under disability and failing to comply with an order or signal of a police officer. The court of appeals affirmed, concluding that Defendant's constitutional right to a speedy trial was not violated during the trial court's remand proceedings. The Supreme Court reversed and vacated Defendant's convictions, holding that all four factors under Barker v. Wingo, 407 U.S. 514 (1972) weighed in Defendant's favor. View "State v. Long" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus, holding that the court of appeals did not err.Appellant, an inmate, was serving a sentence of fifteen years to life for the murder of Ray Emerson. In 2012, Appellant received a copy of the coroner's complete report on the autopsy on the body of Ray. In 2014, Appellant requested photographs of Ray's injuries. The office of the medical examiner did not provide the photographs. In 2019, Appellant filed a petition requesting a writ of mandamus to compel the office to provide photographs of Ray's stab wounds, X-rays of the stab wounds, Ray's death certificate, and a signed autopsy report. The court of appeals granted the office's motion to dismiss. The Supreme Court affirmed, holding that the court of appeals was correct to deny Appellant's request for a writ of mandamus. View "State ex rel. Bandy v. Gilson" on Justia Law

The Supreme Court affirmed the decision of the Public Utilities Commission finding that Suburban Natural Gas Company failed to prove the allegation in its complaint that Columbia Gas Company of Ohio, Inc. had improperly used one of its demand-side management (DSM) programs to unlawfully gain an anticompetitive advantage over Suburban, holding that Suburban failed to demonstrate reversible error.Suburban and Columbia each provided natural-gas distribution service to customers in southern Delaware County. Under the DSM program at issue in this case, Columbia was authorized to offer cash incentives directly to residential builders to construct homes that exceeded certain energy efficiency standards. Suburban filed a complaint alleging that Columbia used this program to pay financial incentives to a home builder to displace Suburban as the provider of natural gas to a planned residential subdivision. The Commission entered an order finding that Suburban had failed to prove the allegations in the complaint. The Supreme Court affirmed, holding that Suburban failed to demonstrate that the Commission erred in deciding the complaint in Columbia's favor. View "Surburban Natural Gas Co. v. Columbia Gas of Ohio, Inc." on Justia Law

The Supreme Court held that a common pleas court has subject-matter jurisdiction to determine whether an easement granting a public utility the right to trim, cut and remove trees, limbs, underbrush or other obstructions permits the public utility to use herbicide to control vegetation within the easement.At issue was whether a public utility may remove vegetation from an easement by use of herbicide. The court of common pleas dismissed this matter as falling within the exclusive jurisdiction of the Public Utilities Commission of Ohio (PUCO). The court of appeals reversed. The Supreme Court affirmed in part and reversed in part, holding (1) this case was not within the exclusion jurisdiction of the PUCO and may be heard and decided by the court of common pleas; and (2) the court of appeals went beyond the narrow issue presented on appeal when it examined the merits of the case and determined that the language of the easements was ambiguous. View "Coder v. Ohio Edison Co." on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the trial court's judgment ordering Michael Knab to make restitution to the City of Centerville, holding that a municipality is not a victim and has no right to restitution under Ohio Const. Art I, 10a, a provision known as Marsy's law.Knab was found guilty of making a false report to law enforcement and improper use of the 9-1-1 emergency system. The trial court ordered Knab to pay restitution to Centerville for the costs it had incurred responding to Knab's 9-1-1 call. The court of appeals affirmed Defendant's convictions but vacated the restitution order, holding that Centerville was not a victim for purposes of restitution when it was carrying out its official duties. The Supreme Court affirmed, holding that a municipal corporation does not qualify as a victim under Marsy's Law and is not entitled to restitution under that provision. View "Centerville v. Knab" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing Defendant's sentence of twenty-five years to life in prison for rape based on the trial court's finding that Defendant had compelled the victim to submit by force, holding that the Sixth Amendment requires that such a finding be made by a jury.Defendant was convicted of rape of a child under the age of thirteen. At a second resentencing, the trial court sentenced Defendant to twenty-five years to life under Ohio Rev. Code 2971.03(B)(1)(c). The court of appeals reversed, holding that Defendant's sentence was not authorized because none of the prerequisites for such a sentence under Ohio Rev. Code 2971.03(B)(1)(c) was present and that permitting a trial court to make a finding of force for the purpose of imposing a sentence under the statute would violate the Sixth Amendment based on Alleyne v. United States, 570 U.S. 99 (2013). The Supreme Court affirmed, holding that Alleyne requires that a finding that the victim was compelled to submit by force or that one of the other factors under subsection (B)(1)(c) is present be made by a jury. View "State v. Bowers" on Justia Law

The Supreme Court reversed the opinion of the court of appeals reversing the trial court's decision granting summary judgment in favor of a teacher and school officials on Plaintiffs' complaint alleging that Defendants were reckless in addressing the alleged bullying of a kindergartener by another student, holding that Defendants did not act in perverse disregard of a known risk.In granting summary judgment for Defendants, the trial court found that they were immune from liability because the family had failed to establish that a genuine issue of material fact existed as to whether Defendants disregarded a known risk or obvious risk of harm to the kindergartener. The court of appeals reversed, finding that a genuine issue of material fact existed with respect to whether Defendants had been reckless. The Supreme Court reversed, holding that Defendants did not act in perverse disregard of a known risk, and therefore, Defendants' conduct was not reckless. View "A.J.R. v. Lute" on Justia Law