Justia Ohio Supreme Court Opinion Summaries

The Supreme Court vacated this Court's denial of Defendant's motion to supplement and remanded the case to the court of appeals to consider the issue of whether Defendant knowingly, intelligently, and voluntarily waived his right to trial counsel.Defendant filed a motion to supplement the record with the transcript of a hearing, during which Defendant signed a waiver of his right to trial counsel. The transcript had not been included in the record considered by the court of appeals, which overruled Defendant's argument that he did not knowingly, intelligently, and voluntarily waive his right to counsel. The Supreme Court denied the motion to supplement, but, on further consideration, vacated the denial and granted the motion to supplement the record with the transcript of the hearing. Because the court of appeals was not privy to the complete record of the hearing, the Supreme Court remanded the cause to the court of appeals to render an opinion, upon its review of the supplemented record, the issue of whether Defendant knowingly, intelligently, and voluntarily waived his right to counsel. View "State v. Jones" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Plaintiff's complaint for a writ of mandamus for noncompliance with Ohio Rev. Code 2969.25(A), holding that where the court's sole basis for dismissing the complaint may have been the result of a docketing error, the complaint should not have been dismissed.When Appellant, an inmate, did not get the desired response to his public-records requests he filed a complaint for a writ of mandamus. The court of appeals dismissed the complaint based on Appellant's alleged failure to file an affidavit of prior actions, as required by Ohio Rev. Code 2969.25(A). The Supreme Court reversed and remanded the case for further proceedings, holding that where the time-stamped affidavit supported Appellant's allegation that he complied with the statute and that the clerk's office failed to place the affidavit in the court file, the court of appeals erred in dismissing the complaint. View "State ex rel. Ware v. Pureval" on Justia Law

The Supreme Court denied the writ of mandamus sought by Douglas Bobovnyik to compel the Mahoning County Board of Elections to certify his name to the November 3, 2020 ballot as an independent candidate for the office of Mahoning County Sheriff, holding that the board did not abuse its discretion or disregard applicable law.The board found Bobovnyik ineligible to be a candidate for the officer of Mahoning County Sheriff because (1) Bobovnyik had not demonstrated that he had resided in Mahoning County for the year immediately preceding March 16, 2020, as required under Ohio Rev. Code 311.01(B)(2); and (2) the board had not received the results of Bobovnyik's background check, as required under Ohio Rev. Code 311.01(B)(6). Bobovnyik subsequently filed this mandamus action to compel the board to place his name on the ballot. The Supreme Court denied the writ, holding that the board's residency determination alone was sufficient to prevent Bobovnyik's name from being placed on the ballot. View "State ex rel. Bobovnyik v. Mahoning County Board of Elections" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against the warden of the Toledo Correctional Institution, holding that the court of appeals correctly dismissed Appellant's petition for a writ of habeas corpus.In dismissing the petition, the court of appeals held that the petition was barred by res judicata and that Appellant had an adequate remedy at law to assert his claims. The court further determined that Appellant had failed to file an affidavit of prior civil actions, as required by Ohio Rev. Code 2969.25(A). The Supreme Court affirmed, holding (1) the court of appeals correctly noted that Appellant's petition was subject to dismissal for his failure to comply with section 2969.25(A); and (2) Appellant was not entitled to file a supplemental brief. View "McDougald v. Bowerman" on Justia Law

The Supreme Court denied Jerone McDougald's motion for mediation and his request for a writ of mandamus seeking to compel Sonrisa Sehlmeyer, the administrative assistant to the warden at the Toledo Correctional Institution, to produce documents pursuant to a public-records request, holding that McDougald did not demonstrate that he had a clear legal right to the requested relief and that Sehlmeyer had a clear legal duty to provide that relief.Sehlmeyer responded to McDougald's public-records request with a notation indicating the number of pages of each requested record and the total amount required for the request. McDougald did not follow up with a cash slip or indication that he was still seeking to inspect the documents. Rather, McDougald filed the present complaint seeking a writ of mandamus and requesting an award of statutory damages and court costs. McDougald also filed a motion asking to submit this case to mediation. The Supreme Court denied all requests, holding that where the institution offered to make the records available, McDougald was not entitled to his requested relief. View "State ex rel. McDougald v. Sehlmeyer" on Justia Law

The Supreme Court reversed the judgment of the court of appeals to the extent that the court remanded this case to the trial court to correct an entry imposing post release control, holding that the sentencing entry did not include notice of the consequences of violating postrelease control, but that failure rendered the sentence voidable, not void.After the court of appeals affirmed Defendant's convictions and sentence Defendant filed a motion to vacate and release from postrelease control, arguing that the trial court had failed properly to impose postrelease control and, therefore, that part of his sentence was void. The court of appeals remanded the case to the trial court to issue a nunc pro tunc entry correcting the deficiency in the judgment entry, as defined in State v. Grimes, 85 N.E.3d 700 (2017). The Supreme Court reversed, holding (1) when the sentencing court has jurisdiction to proceed to judgment, sentencing errors in imposing postrelease control render the sentence voidable, and the doctrine of res judicata will apply to collateral attacks on the sentence; and (2) Defendant's collateral attack on his sentence was barred by res judicata. View "State v. Hudson" on Justia Law

The Supreme Court answered questions certified by the United States District Court for the Northern District of Ohio, Eastern Division regarding whether a conviction is a condition precedent to civil liability pursuant to Ohio Rev. Code 2307.60.Plaintiff's complaint asserted claims for civil liability pursuant to section 2307.60 for alleged violations of three criminal statutes: Ohio Rev. Code 2921.05 (retaliation), Ohio Rev. Code 2921.03 (intimidation), and Ohio Rev. Code 2921.45 (interfering with civil rights). Defendants filed a motion to dismiss for failure to state a claim because they had not been convicted of the underlying criminal offenses. The federal court denied the motions to dismiss and then certified questions to the Supreme Court. The Supreme Court answered (1) section 2307.60's creation of a civil cause of action for injuries based on a "criminal act" does not require an underlying criminal conviction; and (2) a criminal conviction is not a condition precedent to a civil claim pursuant to section 2921.03. View "Buddenberg v. Weisdack" on Justia Law

The Supreme Court denied the writ of mandamus sought by Relator seeking to compel the production of public records, holding that the evidence established that Respondents did not possess documents responsive to Relator's public-records requests.Relator, an inmate, sent a public-records request requesting several documents. Relator later filed his complaint for a writ of mandamus alleging that he had largely not been provided any documents he sought. The Supreme Court denied Relator's request, holding that Relator's evidence that Respondents had documents responsive to his requests was unpersuasive. View "State ex rel. Hedenberg v. North Central Correctional Complex" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Plaintiff's motion for a new trial, holding that the court of appeals erred when it held that the trial court should have ordered a new trial in this medical malpractice case.Plaintiff filed a wrongful death and medical malpractice action against Defendants. The case proceeded to trial. The jury began deliberations on Friday at 11 a.m. At 10 p.m. the jurors reached a verdict in the defense's favor. One month after the trial, the trial court received a letter from one of the jurors saying that she regretted her vote and had compromised her beliefs to avoid having to return to court the following week. The trial court denied Plaintiff's motion for a new trial without considering the juror's letter. The court of appeals reversed, concluding that Ohio R. Evid. 606(B) did not preclude the court from considering the letter and that the trial court's denial of Defendant's motion for mistrial was an abuse of discretion. The Supreme Court reversed, holding (1) the trial court properly refused to consider the juror letter; and (2) the trial court properly refused to order a new trial. View "Jones v. Cleveland Clinic Foundation" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court denying Defendant's motion to withdraw his guilty pleas, holding that Defendant did not meet his burden of establishing that he would not have entered a guilty plea but for the erroneous advice of his plea-stage counsel.Defendant pleaded guilty to sexual battery and attempted induction. Defendant later filed a motion to withdraw his guilty pleas on the grounds that his counsel provided improper advise as to the potential immigration consequences of his pleas. The trial court denied the motion. The court of appeals reversed, holding that counsel was deficient for not "definitively" determining the deportation consequences of Defendant's plea. The Supreme Court reversed, holding that Defendant did not meet his burden of demonstrating that but for his counsel's erroneous advice as to the possibility of relief from deportation he would not have pleaded guilty and would have insisted on going to trial. View "State v. Bozso" on Justia Law