Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus on the grounds that his claim lacked merit, holding that Appellant was not entitled to immediate release.Appellant was convicted of felonious assault and sentenced to an indeterminate prison term of eight to twenty-five years in prison. In his habeas corpus petition, Appellant alleged that he had served his prison sentences and was entitled to immediate release. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that because Appellant will not complete his lawfully imposed prison sentences until December 31, 2022, he was not entitled to immediate release. View "State ex rel. Herring v. Wainwright" on Justia Law

The Supreme Court reversed the judgment of the court of appeals granting summary judgment to the State and denying AWMS Water Solutions, LLC's petition for a writ of mandamus to compel the Ohio Department of Natural Resources and others (collectively, the State) to initiate property-appropriation proceedings, holding that genuine issues of material fact remained regarding whether AWMS had suffered a total or partial taking.AWMS, a disposer of waste from oil and gas production and drilling sites, obtained permits to drill and inject saltwater in wells on its property. After an earthquake occurred, AWMS was ordered to suspend its operations at one of its wells. In its petition for a writ of mandamus, AWMS alleged that a suspension order effected a governmental taking of its property requiring the State to pay just compensation. The court of appeals granted summary judgment for the State and denied the mandamus petition. The Supreme Court reversed, holding (1) AWMS was justified in pursuing compensation through a takings action and that its claim was ripe at the time it instituted its action; and (2) there was a genuine issue of material fact concerning whether the State's suspension of operations at the well deprived AWMS of all economically beneficial use of its leasehold. View "State ex rel. AWMS Water Solutions, LLC v. Mertz" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction for sexually abusing his granddaughter, holding that acquitted-act evidence was admitted for a proper purpose under Evid.R. 404(B).During trial, the trial court allowed the State to introduce "other acts" evidence that Defendant had previously molested his daughter under similar circumstances. Defendant was put on trial for these allegations but was ultimately acquitted. On appeal, Defendant asked the trial court to categorically rule that admitting evidence related to crimes for which a defendant has been acquitted violates the Double Jeopardy Clause of the Ohio Constitution. The Supreme Court rejected the challenge, holding (1) the Double Jeopardy Clause does not impose a per se bar to the use of other-acts evidence for which the defendant was previously acquitted; and (2) because Defendant placed his intent at issue, the trial court properly admitted evidence of the prior sexual-assault allegations. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing Defendant's convictions of two counts of rape, holding that the trial court erred by admitting "other acts" evidence that Defendant had sexually abused his stepdaughter when she was a child.Defendant was convicted of raping an adult female acquaintance. During trial, the trial court allowed the State to present evidence that Defendant had victimized his former stepdaughter as a child. The court of appeals reversed Defendant's convictions, concluding that the evidence of Defendant's abuse of his stepdaughter constituted improper other-acts evidence and was inadmissible under Evid.R. 404(B). The Supreme Court affirmed, holding that the evidence of Defendant's other acts constituted improper propensity evidence, and the trial court erred in admitting it. View "State v. Hartman" on Justia Law

The Supreme Court reversed the order of the Public Utilities Commission of Ohio (PUCO) determining that Direct Energy Business, LLC had established that Duke Energy Ohio, Inc.'s failure to provide accurate readings of the generation usage of one of Direct's customers constituted inadequate service, holding that Duke Energy was not acting as a public utility when serving as Direct's meter-data-management agent.Direct purchased electric generation services from the operator of a wholesale power market and resold them to end-use customers through Duke Energy's distribution system. Duke Energy acted as Direct's meter-data-management agent, providing electric usage data about Direct's customers to the wholesale market operator, which then used the data to invoice Direct for its purchases. When Duke Energy failed to calculate usage data for one of Direct's large customers, Direct filed a complaint against Duke Energy with the PUCO. The PUCO ruled in favor of Direct. The Supreme Court reversed and remanded to the PUCO with instructions for it to dismiss Direct's complaint, holding (1) the PUCO lacked jurisdiction over this matter because PUCO's jurisdiction is confined to the supervision of "public utilities"; and (2) Duke Energy did not act as a public utility under the facts of this case. View "In re Complaint of Direct Energy Business, LLC v. Duke Energy Ohio, Inc." on Justia Law

The Supreme Court denied Relator's requested writ of mandamus seeking to compel Respondent to produce a document pursuant to a public records request and to pay statutory damages and court costs, holding that Respondent provided a complete response to Relator's public records request.In addition to Relator's mandamus petition and request for damages and court costs, Relator filed unopposed motions seeking leave to amend his complaint and leave to submit additional facts. The Supreme Court denied the writ, both motions, and the requests for statutory damages and court costs, holding (1) Relator did not show that Respondent failed to fulfill any of her obligations as a public-records custodian; (2) Defendant was not entitled to an award of court costs or statutory damages; and (3) both motions for leave are denied. View "State ex rel. McDougald v. Sehlmeyer" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus ordering the Industrial Commission to vacate an award of medical-service reimbursement to Diana Garringer for a right reverse total-shoulder arthroplasty, holding that the Commission did not abuse its discretion.Garringer injured her right shoulder while working for Omni Manor. The next year, the Commission granted Garringer's request for medical-service reimbursement for a reverse total-shoulder arthroplasty. Omni Manor requested a writ of mandamus ordering the Commission to vacate its order granting the reimbursement request. The court of appeals denied the request. The Supreme Court affirmed, holding (1) the Commission correctly applied the standard set forth in State ex rel. Miller v. Industrial Commission, 643 N.E.2d 113 (Ohio 1994); and (2) the Commission did not abuse its discretion in considering certain evidence. View "State ex rel. Omni Manor, Inc. v. Industrial Commission" on Justia Law

The Supreme Court held that Section 858.01 of the Codified Ordinances of the Village of Put-In-Bay does not impose an unconstitutional tax on motor vehicles.The Village filed separate criminal complaints against Defendants, who operated businesses that made motorized golf cars available for rent within the Village, for failing to pay the annual license fee on their golf carts. The trial court dismissed the criminal complaints on the basis that section 858.01 is for a similar purpose as the annual state license tax levied on the operation of motor vehicles under Ohio Rev. Code 4503.02 and the local government tax permitted by Ohio Rev. Code 4504.02 and 4504.06. The court of appeals reversed, concluding that section 858.01 was not preempted by state law and did not violate Ohio Const. art. XII, 5a. The Supreme Court affirmed, holding (1) the tax is a constitutional exercise of the municipality's right to tax; and (2) section 858.01 does not impose an unconstitutional tax. View "Put-in-Bay v. Mathys" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Plaintiffs' appeal from the trial court's dismissal of Plaintiffs' complaint on the basis that a dismissal without prejudice based on forum non conveniens is not a final, appealable order, holding a trial court's order dismissing a case without prejudice based on the doctrine of forum non conveniens is not a final, appealable order pursuant to Ohio Rev. Code 2505.02.Plaintiffs were obligated under Kentucky law to pay workers' compensation benefits to a worker who was injured at Defendant's facility. They subsequently filed a lawsuit against against Defendant in the Cuyahoga County Court of Common Pleas in Ohio, seeking to recover the amount that they had been required to pay. Defendant filed a motion to dismiss the complaint based on the doctrine of forum non conveniens, arguing that the action should be filed in the Circuit Court in Grant County, Kentucky. The trial court dismissed the case, without prejudice, based on forum non conveniens. The court of appeals dismissed Plaintiffs' appeal on the basis that a dismissal without prejudice based on forum non conveniens is not a final, appealable order. The Supreme Court affirmed, holding that the dismissal in this case was not a final, appealable order. View "Crown Services, Inc. v. Miami Valley Paper Tube Co." on Justia Law

The Supreme Court granted a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction and its director (collectively, DRC) to revise their calculation of Charles Fraley's prison sentence, holding that Fraley was entitled to a writ of mandamus compelling DRC to correct its records.In this case, the sentencing court imposed an aggregate sentence of ten years. However, DRC computed Fraley's sentence to be an aggregate term of thirteen years. In his petition for a writ of mandamus Fraley argued that DRC was under a clear legal duty to follow the sentencing judge's entries. The Supreme Court agreed, holding (1) Fraley did not have an alternative remedy that would preclude the possibility of a writ of mandamus; and (2) DRC had a clear legal duty to carry out the sentence that the trial court imposed. View "State ex rel. Fraley v. Ohio Department of Rehabilitation & Correction" on Justia Law