Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court adopted the recommendation of the master commissioner and granted Petitioner's petition for writ of habeas corpus challenging the amount of his pretrial bond, holding that the master commissioner properly stated the facts and applied the law.Petitioner was in jail awaiting trial on multiple charges when he filed his habeas petition. The Supreme Court referred the matter to a master commissioner to conduct a hearing to determine whether Petitioner was being held unlawfully due to an excessive bond. The master commissioner concluded that the $1,000,000 bond on which Petitioner was being held was excessive and recommended modifying the bail to $200,000. The Supreme Court adopted the recommendation and granted the petition for writ of habeas corpus but with certain additional nonfinancial conditions. View "Mohamed v. Eckelberry" on Justia Law

The Supreme Court dismissed as moot this original action for writ of mandamus to compel Respondents to disregard Am.Sub.S.D. No. 120 (S.B. 120), holding that Relators no longer have a legally cognizable interest in the outcome of this case and that intervening legislation has rendered this cause moot.S.B. 120 amended the 2020-2021 biennial budget bill to appropriate $10 million to fund scholarships under the Ohio Educational Choice Scholarship Program (EdChoice) for first-time eligible applicants. Relators brought this action seeking to compel Respondents to disregard S.B. 120 and administer the EdChoice program under the law as it existed prior to S.B. 120's passage. The Supreme Court dismissed the action, holding that the passage of time and intervening legislation have rendered this action moot. View "State ex rel. Citizens for Community Values, Inc. v. DeWine" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated murder and sentence of death, holding that no prejudicial error occurred in the proceedings below.Specifically, the Supreme Court held (1) the trial court had jurisdiction over the course-of-conduct death-penalty specification; (2) the trial court did not abuse its discretion in admitting evidence relating to the murder; (3) Defendant was not denied his right to an impartial jury due to the seating of certain jurors; (4) the trial court did not deny Defendant his rights to due process and a fair trial by requiring him to wear leg shackles during the trial; (5) the trial court did not err in ruling that an audiovisual-forensics analyst was a lay witness and allowing him to testify; (6) the trial court did not err in admitting Defendant's videotaped phone conversations; (7) the trial court did not err in admitting autopsy photographs into evidence; (8) no plain error occurred from the prosecutor's statements during the mitigation phase of trial; (9) Defendant received effective assistance of counsel; and (10) Defendant's sentence was constitutional. View "State v. Froman" 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 was correct in determining that Appellant's petition failed to state a claim cognizable in habeas corpus.Appellant was convicted of several felony drug-related offenses and sentenced to an aggregate term of thirty-two years' imprisonment. Appellant filed a petition for a writ of habeas corpus alleging that insufficient evidence supported his convictions. The court of appeals dismissed the petition on the grounds that it failed to state a claim cognizable in habeas corpus. The Supreme Court affirmed, holding that the court of appeals did not err. View "Carter v. May" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's habeas corpus petition against the warden of the Marion Correctional Institution (MCI), holding that Appellant's petition was barred by res judicata.Appellant, an inmate at MCI, filed a successive petition for a writ of habeas corpus alleging that his maximum aggregate sentence had expired. The court of appeals dismissed the action, holding that habeas corpus does not lie because Appellant's maximum aggregate sentence will not expire until June 2023 and that the petition was barred by res judicata as a successive habeas petition. The Supreme Court affirmed, holding that the court of appeals properly granted summary judgment on res judicata grounds. View "Dailey v. Wainwright" on Justia Law