Justia Ohio Supreme Court Opinion Summaries

The Supreme Court denied a writ of mandamus sought by Relators seeking to compel the placement of four referendum petitions on the November 2020 ballot, holding that Relators failed to present evidence establishing their right to relief.King received petitions calling for a referendum on two meter ordinances, an ordinance authorizing the city manager to enter into an extension of the employment contract with the current law director, and an ordinance authorizing the issuance of bonds to fund the purchase and renovation of real property for use as a municipal building. King questioned whether the ordinances were subject to referendum. Relators then filed this mandamus complaint. The Supreme Court denied a writ of mandamus, holding that Relators failed to present evidence establishing their right to relief by clear and convincing evidence. View "State ex rel. Luonuansuu v. King" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus ordering the Industrial Commission to grant Appellant's request for permanent-total-disability (PTD) compensation, holding that the court of appeals correctly denied the writ.The Commission found that Appellant had voluntarily abandoned the workforce and denied his request for PTD compensation. Appellant asked the court of appeals for a writ of mandamus ordering the Commission to vacate its decision and grant his application for PTD compensation. The Commission denied the writ, concluding that the Commission did not abuse its discretion. The Supreme Court affirmed, holding that the Commission's decision that Appellant voluntarily abandoned the workforce was supported by some evidence in the record. View "State ex rel. Bonnlander v. Hamon" on Justia Law

The Supreme Court denied Petitioner's request for a writ of mandamus arguing that he was entitled to unredacted copies of the Southern Ohio Correctional Facility's most recent shift-assignment duty rosters, holding that the documents fell under the security-records exemption to the Public Records Act.Petitioner, an inmate, requested copies of documents that detailed the assignment of prison guards to various posts within the prison. Larry Greene, the prison's public-records custodian, turned over the records but redacted the majority of the information. Petitioner requested a writ of mandamus. The Supreme Court denied the writ, holding (1) because the documents were security records, they were exempt from disclosure under the Public Records Act, and Greene had no legal duty to turn them over; and (2) none of the exemptions to the Public Records Act applied. View "McDougald v. Greene" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's judgment denying jail-time credit for the days Defendant was on postconviction house arrest and postconviction electronic monitoring, holding that Defendant was not entitled to jail-time credit for these days.Defendant pled guilty to a charge involving criminal gang activity and was sentenced to community-control sanctions. Defendant was later placed on house arrest after he violated terms of his community control and was then placed on electronic monitoring after new charges were brought against him. During a hearing, Defendant filed a motion asserting that he was entitled to jail-time credit for the time he was on standard house arrest and electronic monitoring. The trial court denied the motion and imposed a sentence. The appellate court reversed, concluding that Defendant was entitled to jail-time credit for the time he was on house arrest and electronic monitoring. The Supreme Court reversed, holding that Ohio Rev. Code 2969.191(A) is plain and unambiguous, limits a jail-time credit to specific types of confinement, and does not provide for a reduction in sentence for a term of postconviction house arrest or electronic monitoring imposed for violating community-control sanctions. View "State v. Reed" on Justia Law

The Supreme Court denied the writ of prohibition sought by Relator to prevent the Trumbull County Board of Elections from holding a hearing under Ohio Rev. Code 3501.11(J) and (Q), holding that Relator failed to show that the board was about to exercise quasi-judicial power, that the hearing was unauthorized by law, or that she lacked an adequate remedy in the ordinary course of the law.Section 3501.11(J) empowers the board to investigate violations of election law and report its findings to the secretary of state or the prosecuting attorney. Section 3501.11(Q) empowers the board to investigate the residence qualifications of electors. Relator, who won the Republican nomination to the office of Trumbull County Commissioner and was certified to appear on the November 3, 2020 ballot as a candidate, told Relator that it would hold a public hearing to address allegations regarding Relator's residence and eligibility as an elector during the 2019 through 2020 school year and Relator's alleged misstatements regarding the same. Relator filed a writ of prohibition seeking to prevent the board from holding the hearing.The Supreme Court denied the writ, holding that Relator failed to establish any of the elements showing that she was entitled to a writ of prohibition. View "State ex rel. Frenchko v. Trumbull County Board of Elections" on Justia Law

The Supreme Court denied the writs of mandamus sought by Relators, Marie Nauth and the group Concerned Citizens of Medina City (CCMC), seeking an order directing members of the Medina County Board of Elections (collectively, the Board) to certify as valid forty-seven signatures that Relators say the Board invalidated as not genuine, holding that Relators did not meet their burden to show an abuse of discretion by the Board.Relators filed a referendum petition that fell forty-four signatures short of qualifying for the November 3, 2020 general election ballot. Relators then commenced this action seeking a writ of mandamus that would direct the Board to reexamine the signatures on the referendum petition and certify as valid the signatures of qualified electors that they signed the referendum petition. The Supreme Court denied the writs, holding that Relators failed to prove by clear and convincing evidence that the forty-seven signatures at issue were invalidated in the first place and for what reasons. View "State ex rel. Nauth v. Dirham" on Justia Law

The Supreme Court held that when an at-will employee consents, without objection, to the collection of his or her urine sample under the "direct-observation method," the at-will employee has no cause of action for common-law invasion of privacy.Plaintiffs were former and current at-will employees of Defendant. Defendant had a workplace substance-abuse policy requiring employees to submit a urine sample for drug testing under the direct-observation method, under which a same-sex monitor was required to accompany the employee to the restroom to visually observe the employee produce the urine sample. While Plaintiffs did not know at the time they consented that their urine samples would be collected under the direct-observation method they proceeded with the drug test under the direct-observation method without objection. Plaintiffs filed a complaint alleging that Defendant violated their privacy by requiring them to submit their urine samples under the direct-observation method. The trial court granted judgment for Defendant, concluding that Plaintiffs had not stated a valid claim for invasion of privacy. The court of appeals reversed. The Supreme Court reversed, holding that the trial court correctly dismissed Plaintiffs' invasion-of-privacy claim for failure to state a claim upon which relief can be granted. View "Lunsford v. Sterilite of Ohio, LLC" on Justia Law

The Supreme Court denied a writ of prohibition to prevent the three members of a board of county commissioners from going forward with a show-cause hearing to consider the removal of a member of the board of trustees of the county hospital, holding that the commissioners did not patently and unambiguously lack jurisdiction to proceed with the show-cause hearing.The Morrow County Board of Commissioners claimed that the authority to appoint and remove members of the Morrow County Hospital Board of Trustees was a five-member body, with each commissioner having one vote. Patrick Drouhard, the chairman of the Board of Trustees, claimed that the appointing authority was a three-member body, with the board of commissioners having a single collective vote and the other votes belonging to the judges of the Morrow County Court of Common Pleas. When the Commissioners sought to schedule a show-cause hearing to remove Drouhard as chairman of the Hospital Board Drouhard filed this complaint for a writ of prohibition. The Supreme Court denied the writ, holding (1) the three commissioners constitute the majority of the appointing authority that is empowered by law to remove a member of the county hospital board; and (2) Drouhard possessed an adequate remedy by way of an appeal following the show-cause hearing. View "State ex rel. Drouhard v. Morrow County Board of Commissioners" on Justia Law

In this medical malpractice action, the Supreme Court reversed the judgment of the court of appeals reversing the trial court's grant of summary judgment in favor of Defendants, holding that Plaintiff could not rely on the savings statute when he filed this action just before the expiration of the statute of limitations but did not obtain service within one year or dismiss the action during that period.Although Plaintiff had initially filed this lawsuit within the limitations period, he neither obtained service on Dr. Eric Humphreys within one year, nor did he dismiss his lawsuit during that time. As a consequence, the trial court ruled that Dr. Humphreys was dismissed with prejudice from the lawsuit because Plaintiff's claims against him were time barred. Concluding that the remaining defendants could only be vicariously liable, the court found that any liability of those parties was extinguished. The court of appeals reversed, holding that the savings statute applied to Plaintiff's claim against Dr. Humphreys. The Supreme Court reversed, holding that because there was neither a dismissal otherwise than on the merits nor the filing of a new action, the savings statute did not apply, and Plaintiff's claim was barred by the statute of limitations. View "Moore v. Mount Carmel Health System" on Justia Law

The Supreme Court affirmed the judgment of the trial court sentencing Defendant to death for the aggravated murders of Casonya C. and Esme K., holding that there was no prejudicial error in the proceedings below.Defendant was found guilty of two aggravated murders and sentenced to death for each aggravated murder. The Supreme Court later vacated the death sentences and remanded the case to the trial court for resentencing. On remand, the trial court again sentenced Defendant to death for the aggravated murders of Casonya and Esme. The Supreme Court affirmed, holding (1) the trial court did not err by denying Defendant's request for individual sequestered voir dire; (2) the trial court did not commit an obvious error in failing to dismiss a prospective juror sua sponte; (3) Defendant did not receive ineffective assistance of counsel during the resentencing hearing; (4) any error with respect to the prosecutor's comments during closing arguments did not prejudicially affect Defendant's substantial rights; and (5) the death sentences in this case were proportionate and appropriate. View "State v. Kirkland" on Justia Law