Justia Ohio Supreme Court Opinion Summaries

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

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