Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals in this criminal case, holding that Ohio Rev. Code 2913.61(C)(1) unambiguously allows for the aggregation of multiple theft offenses involving one victim into a single count, regardless of the status of the victim.In connection with multiple alleged incidents of passing fraudulent checks at four separate banks, Defendant was convicted of four counts of theft in violation of Ohio Rev. Code 2913.02(A)(3). In accordance with section 2913.61(C)(1), each theft count aggregated the multiple instances of theft alleged against each respective bank. The court of appeals vacated Defendant's sentences in part and otherwise affirmed. In so doing, the court held that section 2913.61(C)(1) does not limit the aggregation of theft offenses under section 2913.02 to offenses involving victims who are disabled adults, elderly persons, or military persons. The Supreme Court affirmed, holding that the unambiguous language of section 2913.61(C)(1) allows aggregation of theft offenses, regardless of the status of the victim. View "State v. Pettus" on Justia Law

The Supreme Court vacated its earlier judgment granting Relator a writ of mandamus and entered a judgment denying the writ, holding that because a transcript could not be located, the earlier judgment cannot be executed.Relator filed an original action seeking a writ of mandamus to compel Respondent, a former Marion County court reporter, to inform him of the cost to obtain a copy of his 2009 sentencing transcript. The Supreme Court granted the writ. The Court then vacated its judgment, holding that where the only evidence indicating that a transcript of Relator's sentencing hearing existed was the trial court's incorrect statement to that effect, this Court's previous judgment could not be executed. View "State ex rel. Newsome v. Hack" on Justia Law

The Supreme Court denied a writ of prohibition sought by Relator to bar the Warren County Board of Elections from placing certain tax-reduction measures on the November 2020 ballot, holding that the Board did not abuse its discretion or disregard applicable law by placing the petitions on the ballot.The tax levies at issue allow supported the Mason City School District and sought to reduce nine tax levies by .01 mills. Relator filed a protest against placing the tax-reduction measures on the ballot. The Board denied the protest. Thereafter, Relator filed a complaint for a writ of mandamus. The Supreme Court denied the writ, holding that the the statutory requirements for ballot access were met, and therefore, the Board properly placed the petitions on the ballot. View "State ex rel. Meyer v. Warren County Board of Elections" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of mandamus seeking to compel the Ohio Department of Rehabilitation and Correction (DRC) to conduct a hearing concerning an alleged use of force incident, holding that because Appellant did not strictly comply with Ohio Rev. Code 2969.25(A) the court of appeals correctly dismissed his petition.Appellant alleged in his petition that he had suffered injuries when a prison officer used a chemical spray on him while he was incarcerated. The court of appeals granted DRC's motion to dismiss, concluding that Appellant had not satisfied section 2969.25(A). The Supreme Court affirmed, holding that Appellant failed to comply with section 2969.25(A) and that the court of appeals was right to dismiss Appellant's petition. View "State ex rel. Russell v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court held that a trial court need not find a change in circumstances in order to designate a parent the residential parent and legal custodian of a minor child after terminating a shared parenting plan and decree.The Supreme Court affirmed the judgment of the court of appeals upholding the decision of the juvenile division of the court of common pleas that terminated a shared parenting plan between Father and Mother and designated Mother as the sole residential and legal custodian of the parties' minor child, holding that, under the plain language of Ohio Rev. Code 3109.04, a trial court is not required to find a change in circumstances but needs only to consider only the best interest of the child when deciding whether the terminate a shared parenting plan and which parent to designate as the residential and custodial parent of a minor child. View "Bruns v. Green" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of habeas corpus for failure to state a claim, holding that the court of appeals did not err.Appellant, an inmate, filed a petition for a writ of habeas corpus alleging that the sentencing judge failed to make the findings required by Ohio Rev. Code 2929.14(C) before imposing consecutive sentences. The court of appeals dismissed the petition, concluding that Appellant's complaint did not state a claim cognizable in habeas corpus. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of law, and therefore, relief was unavailable in habeas corpus. View "McKinney v. Haviland" on Justia Law

The Supreme Court remanded this matter to the trial court to vacate the trial court's decision granting the State's motion to correct Defendant's unlawful sentence eighteen years after the sentence was entered, holding that the State cannot challenge Defendant's voidable sentence through a postconviction motion for resentencing.Defendant pleaded guilty to one count of murder with a three-year firearm specification. Defendant should have been sentenced to an indefinite sentence of fifteen years to life for his murder conviction. The trial court, however, sentenced Defendant to a definite sentence. The State later filed a motion for resentencing. The trial court granted the sentence, and the court of appeals affirmed. The Supreme Court reversed the court of appeals' judgment and remanded the matter for the trial court to vacate the sentencing entry and to reinstate Defendant's original sentence, holding (1) sentences based on an error, including sentences in which a court fails to impose a statutorily mandated term, are voidable if the court imposing the sentence has jurisdiction over the case and the defendant; (2) Defendant's sentence was voidable; and (3) the State cannot challenge a voidable sentence through a postconviction motion for resentencing. View "State v. Henderson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against Allen County Court of Common Pleas Judge Jeffrey Reed, holding that the court of appeals properly dismissed the complaint.Appellant pled no contest to pandering. He subsequently sought to withdraw his plea, but the trial court denied the motion. The court of appeals affirmed. Appellant later filed an original action for a writ of mandamus, asking that a certified search warrant be allowed as part of the record. The court of appeals dismissed the complaint, concluding that Appellant had an adequate remedy in the ordinary course of the law. The Supreme Court affirmed, holding that App.R. 9(E) provides an adequate remedy for correcting a record, thereby foreclosing mandamus relief. View "State ex rel. Martre v. Reed" on Justia Law

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