Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the court of common pleas, juvenile division, which granted permanent custody of A.M. to the Hamilton County Department of Job and Family Services (Department), holding that the juvenile court complied with Ohio Rev. Code 2151.414(D)(1).At issue was the statutory requirement that juvenile courts consider the factors set forth in Ohio Rev. Code 2151.414(D)(1) for determining a child's best interest before granting a motion filed by a private child-placing agency or a public children-services agency for permanent custody of that child. The magistrate in this case granted the Department permanent custody of A.M., finding that A.M. should not be placed with either parent and that an award of permanent custody to the Department was in A.M.'s best interest. The juvenile court adopted the magistrate's decision. The court of appeals affirmed. The Supreme Court affirmed, holding (1) section 2151.414(D)(1) requires a juvenile court to consider all relevant factors in determining the best interest of a child in a permanent custody case; and (2) the record demonstrated that the magistrate and the juvenile court considered the statutory factors. View "In re A.M." on Justia Law

The Supreme Court granted in part and denied in part Jerone McDougald's writ of mandamus to compel Larry Greene to provide documents in response to McDougald's public-records request, holding that McDougald was entitled to a writ of mandamus compelling Greene to allow him personally to inspect two of the three records he sought.McDougald, an inmate at the Southern Ohio Correctional Facility (SOCF), sent a public-records request to Greene, the records custodian at SOCF, requesting to inspect three records. When Greene did not allow the inspection, McDougald filed the present complaint for a writ of mandamus. Also pending was McDougald's motion to consider the exhibits attached to his complaint as substantive evidence and his two motions for leave to amend. The Supreme Court granted the motion to consider evidence, granted in part and denied in part the writ of mandamus, and denied McDougald's request for an award of statutory damages, holding (1) McDougald was entitled to a writ of mandamus with respect to his request for two of the three records he requested; and (2) McDougald was not entitled to statutory damages. View "State ex rel. McDougald v. Greene" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that a cognovit promissory note signed by debtors was defective, holding that the contract, viewed as a whole, put the debtors on notice of the rights they were relinquishing by signing the note.Progressive Polymers, LLC and Darin Bay obtained a loan from Sutton Bank secured by a cognovit promissory note. The note included a confession-of-judgment clause containing a warrant of attorney by which Progressive Polymers and Bay agreed that if they defaulted on the note an attorney could confess judgment against them. Sutton Bank later filed a complaint for a cognovit judgment against Progressive Polymers and Bay, alleging default. The trial court ruled in favor of Sutton Bank and issued the cognovit judgment. The court of appeals vacated the cognovit judgment, concluding that the note did not meet the strict requirements of Ohio Rev. Code 2323.13(D) and was therefore not a valid cognovit note upon which judgment could be entered. The Supreme Court reversed, holding that although cognovit clauses are construed strictly against those seeking to enforce them, courts must still give effect to the clear intent of the parties when interpreting them. View "Sutton Bank v. Progressive Polymers, LLC" on Justia Law

In this case involving a subsidy to offset part of the cost of health insurance that Ohio Public Employees Retirement System (OPERS) provides to retirees receiving an OPERS pension the Supreme Court affirmed the decision of the court of appeals reversing the trial court's dismissal of the action for failure to state a claim, holding that the court of appeals correctly determined that Plaintiff stated a claim under Civ.R. 12(B)(6).Plaintiff filed a class action suit against OPERS arguing that reducing the subsidy of any retiree who is reemployed by a public employer that is a member of the OPERS network violates the Equal Protection Clause of the Ohio Constitution. The trial court dismissed the case under Civ.R. 12(B)(6). The appellate court reversed, holding that Plaintiff stated a claim under Ohio's Equal Protection Clause. The Supreme Court affirmed, holding that Plaintiff alleged facts that, if accepted as true, would entitle him to relief. View "Sherman v. Ohio Public Employees Retirement System" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against Ashland County Court of Common Pleas Judge Ronald Forsthoefel, holding that the court of appeals correctly found that Appellant's complaint failed to state a claim for relief in mandamus.Appellant was found guilty of six drug-related counts, and Judge Forsthoefel sentenced him to an aggregate term of sixty-one months. Appellant later filed a petition seeking a writ of mandamus to compel Judge Forsthoefel to vacate his sentence, merge counts four and five, and resentence him. The court of appeals granted Judge Forsthoefel's motion to dismiss. The Supreme Court affirmed, holding that Appellant had an adequate remedy by way of appeal. View "State ex rel. Olmstead v. Forsthoefel" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's sentence for violating the conditions of his community control, holding that the trial court was within its authority to impose Defendant's full suspended twelve-month prison sentence under the circumstances of this case.As a condition of his community-control sanction Defendant was ordered to complete a drug treatment program. Soon after entering the program, Defendant was kicked out for misconduct. Defendant's probation officer filed a complaint alleging that Defendant had violated the conditions of his community control. Defendant admitted to the alleged violations. The trial court imposed the twelve-month prison term. Defendant appealed, arguing that his failure to complete the programs were technical violations, and therefore, his sentence could not exceed the ninety-day sentencing cap contained in Ohio Rev. Code 2929.15(B)(1)(c)(i). The Supreme Court affirmed, holding (1) the circumstances surrounding Defendant's violations were such that they could not be deemed merely technical in nature; and (2) therefore, the sentencing cap did not apply, and the trial court had discretion to sentence Defendant to a twelve-month prison term. View "State v. Castner" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions for corrupting another with drugs and other offenses but remanding the matter to the trial court for resentencing because the trial court had erred in failing to merge the two convictions for corrupting another with drugs as allied offenses of similar import, holding that the trial court properly instructed the jury on the causation element of the offense of corrupting another with drugs.On appeal, Defendant argued that, when instructing a jury on the causation element of the offense of corrupting another with drugs, the trial court is required to inform the jury that it must find not only that the accused's conduct was the but-for cause of serious physical harm to the victim but also that it was an independently sufficient cause of that harm. The Supreme Court affirmed, holding that because Defendant did not ask the trial court to give that instruction, the propriety of such an instruction was not before the Court in this case. View "State v. Price" on Justia Law

The Supreme Court affirmed the judgment of the Fourth District Court of Appeals dismissing Appellant's complaint for a writ of procedendo against Judge Mark Kuhn of the Scioto County Court of Common Pleas, holding that the dismissal of Appellant's complaint was appropriate under the circumstances.Appellant, an inmate, filed a complaint for a writ of procedendo seeking an order compelling Judge Kuhn to journalize a final judgment of conviction. The Fourth District dismissed Appellant's complaint for lack of jurisdiction. The Supreme Court affirmed on different grounds, holding that the dismissal of Appellant's petition was appropriate because Appellant failed to show a clear legal right to relief in procedendo. View "McDougald v. Kuhn" 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 correctly dismissed the mandamus petition.Appellant pleaded guilty to one count of rape and was sentenced to life imprisonment with parole eligibility after ten years. The trial court later entered a nunc pro tunc judgment of conviction to specify that Appellant's sentence included five years of mandatory postrelease control. Appellant later commenced this mandamus action arguing that his sentence was void. The court of appeals dismissed the action. The Supreme Court affirmed, holding that Appellant had adequate remedies at law that precluded extraordinary relief in mandamus. View "State ex rel. Crangle v. Summit County Common Pleas Court" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that the court of appeals properly determined that Appellant's claim was barred by res judicata.Appellant pleaded guilty to involuntary manslaughter and aggravated robbery and was later released on parole. The Ohio Parole Board later found that Appellant had violated the conditions of his release and revoked his parole. Later that year, Appellant filed a petition for writ of habeas corpus, which the common pleas court dismissed. Appellant subsequently filed a second petition for writ of habeas corpus alleging that the Parole Board lacked authority to revoke his parole. The court of appeals dismissed the petition, concluding that the claim was barred under the doctrine of res judicata. The Supreme Court affirmed, holding that the court of appeals did not err. View "Jones v. Wainwright" on Justia Law