Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of mandamus seeking to compel the Ohio Department of Rehabilitation and Correction (DRC) to conduct a hearing concerning an alleged use of force incident, holding that because Appellant did not strictly comply with Ohio Rev. Code 2969.25(A) the court of appeals correctly dismissed his petition.Appellant alleged in his petition that he had suffered injuries when a prison officer used a chemical spray on him while he was incarcerated. The court of appeals granted DRC's motion to dismiss, concluding that Appellant had not satisfied section 2969.25(A). The Supreme Court affirmed, holding that Appellant failed to comply with section 2969.25(A) and that the court of appeals was right to dismiss Appellant's petition. View "State ex rel. Russell v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court held that a trial court need not find a change in circumstances in order to designate a parent the residential parent and legal custodian of a minor child after terminating a shared parenting plan and decree.The Supreme Court affirmed the judgment of the court of appeals upholding the decision of the juvenile division of the court of common pleas that terminated a shared parenting plan between Father and Mother and designated Mother as the sole residential and legal custodian of the parties' minor child, holding that, under the plain language of Ohio Rev. Code 3109.04, a trial court is not required to find a change in circumstances but needs only to consider only the best interest of the child when deciding whether the terminate a shared parenting plan and which parent to designate as the residential and custodial parent of a minor child. View "Bruns v. Green" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of habeas corpus for failure to state a claim, holding that the court of appeals did not err.Appellant, an inmate, filed a petition for a writ of habeas corpus alleging that the sentencing judge failed to make the findings required by Ohio Rev. Code 2929.14(C) before imposing consecutive sentences. The court of appeals dismissed the petition, concluding that Appellant's complaint did not state a claim cognizable in habeas corpus. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of law, and therefore, relief was unavailable in habeas corpus. View "McKinney v. Haviland" on Justia Law

The Supreme Court remanded this matter to the trial court to vacate the trial court's decision granting the State's motion to correct Defendant's unlawful sentence eighteen years after the sentence was entered, holding that the State cannot challenge Defendant's voidable sentence through a postconviction motion for resentencing.Defendant pleaded guilty to one count of murder with a three-year firearm specification. Defendant should have been sentenced to an indefinite sentence of fifteen years to life for his murder conviction. The trial court, however, sentenced Defendant to a definite sentence. The State later filed a motion for resentencing. The trial court granted the sentence, and the court of appeals affirmed. The Supreme Court reversed the court of appeals' judgment and remanded the matter for the trial court to vacate the sentencing entry and to reinstate Defendant's original sentence, holding (1) sentences based on an error, including sentences in which a court fails to impose a statutorily mandated term, are voidable if the court imposing the sentence has jurisdiction over the case and the defendant; (2) Defendant's sentence was voidable; and (3) the State cannot challenge a voidable sentence through a postconviction motion for resentencing. View "State v. Henderson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against Allen County Court of Common Pleas Judge Jeffrey Reed, holding that the court of appeals properly dismissed the complaint.Appellant pled no contest to pandering. He subsequently sought to withdraw his plea, but the trial court denied the motion. The court of appeals affirmed. Appellant later filed an original action for a writ of mandamus, asking that a certified search warrant be allowed as part of the record. The court of appeals dismissed the complaint, concluding that Appellant had an adequate remedy in the ordinary course of the law. The Supreme Court affirmed, holding that App.R. 9(E) provides an adequate remedy for correcting a record, thereby foreclosing mandamus relief. View "State ex rel. Martre v. Reed" on Justia Law

In this products-liability action, the Supreme Court held that the trial court did not err in granting summary judgment to Amazon.com, Inc., holding that, under the facts of this case, Amazon could not be held liable as a "supplier" under the Ohio Products Liability Act, Ohio Rev. Code 2307.71 et seq.Eighteen-year-old Logan Stiner died after ingesting a fatal dose of caffeine powder that he obtained from his friend, K.K. His friend purchased the caffeine powder on Amazon. Tenkoris, LLC, a third-party vendor, sold the caffeine powder and posted the product on Amazon's website under the storefront name TheBulkSource. After K.K. gave some caffeine powder to Logan, he died of cardiac arrhythmia and seizure from acute caffeine toxicity. Dennis Steiner, the administrator of Logan's estate, brought this action against Amazon, alleging claims under the Ohio Products Liability Act and the Ohio Pure Food and Drug Act. The trial court granted summary judgment for Amazon. The court of appeals affirmed, concluding that Amazon was not a "supplier" as defined in section 2307.71(A)(15). The Supreme Court affirmed, holding that the trial court properly granted summary judgment to Amazon on Plaintiff's product-liability claims. View "Stiner v. Amazon.com, Inc." on Justia Law

The Supreme Court denied Relator's request for a writ of mandamus seeking to compel Respondent to permit him to inspect certain public records, holding that Relator failed to establish by clear and convincing evidence that he was entitled to a writ of mandamus.Relator, an inmate at the Toledo Correctional Institution, send a public-records request to Respondent, the warden's administrative assistant, asking to inspect two use-of-force reports and a review of a particular use-of-force incident. Respondent refused to permit Relator to inspect the requested records due to concerns over safety and security. Relator then brought this action. The Supreme Court denied relief, holding (1) where Relator did not refute the evidence that he presented a security risk, Relator did not establish his entitlement to a writ of mandamus; and (2) Relator was not entitled to statutory damages or court costs. View "State ex rel. McDougald v. Sehlmeyer" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court dismissing the charges filed against Appellant for failure to pay court-ordered child support based on the Supreme Court's decision in State v. Pittman, 79 N.E.3d 531 (Ohio 2016), holding that Pittman did not apply.The State charged Defendant with two counts of nonsupport of defendants under Ohio Rev. Code 2919.21(B). Defendant filed a motion to dismiss, asserting that he could not be prosecuted for violating the statute because he was not subject to a legal support order at the time he was charged. The trial court granted the motion to dismiss based on its interpretation of Pittman. The court of appeals reversed, concluding that Pittman did not apply to the facts of the present case. The Supreme Court affirmed, holding that the trial court erred in dismissing the charges simply because Defendant's child had been emancipated at the time Defendant was charged. View "State v. Brown" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of felony murder based on felonious assault of a child and reckless homicide as a lesser included offense of aggravated murder, holding that the trial court did not err in refusing to provide an instruction on reckless homicide.Defendant was charged with aggravated murder, felony murder, and child endangering. The jury found Defendant guilty of felony murder. As to the aggravated murder charge, the jury found Defendant not guilty, instead finding her guilty of the lesser included offense of reckless homicide. On appeal, Defendant argued that the trial court erred by not giving a reckless homicide instruction as a lesser included offense of felony murder. The court of appeals affirmed. The Supreme Court affirmed, holding (1) because felony murder has no mens rea requirement in regard to the death of a victim, whereas reckless homicide has the mens rea of recklessness, reckless homicide is not a lesser included offense of felony murder; and (2) therefore, the trial court did not err in refusing to give the requested instruction. View "State v. Owens" on Justia Law

The Supreme Court reversed the judgment of the Board of Tax Appeals (BTA) and the court of appeals affirming the decision of the tax commissioner that gross receipts earned by Defender Security Company between January 2011 and December 2013 were Ohio-taxable receipts under the commercial activity tax (CAT) law, holding that Appellant was entitled to relief on its statutory claim.The receipts at issue consisted of payments made to Defender by ADT Security Services, Inc. Defender filed a refund claim seeking the return of $73,334 for commercial activity tax paid on gross receipts for approximately three years. The tax commission denied the refund claim. The BTA agreed with the tax commissioner's conclusion that the proper situs of ADT funding should be Ohio and affirmed. The court of appeals affirmed. The Supreme Court reversed, holding that, under Ohio Rev. Code 5751.033(I), the situs of ADT funding receipts is ADT's physical location outside Ohio. The Court remanded the case to the tax commissioner with instructions that he issue refunds in the amount set forth in the refund claim, plus interest. View "Defender Security Co. v. McClain" on Justia Law