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 mandamus against Holmes County Court of Common Pleas Judge Robert D. Rinfret, holding that the court of appeals correctly determined that Appellant had an adequate remedy in the ordinary course of the law.Appellant, who was serving consecutive prison terms for five convictions, filed a petition for a writ of mandamus arguing that Judge Rinfret improperly sentenced him to a prison term of nine years for his attempted rape conviction instead of the maximum term of eleven years. The court of appeals dismissed the petition, determining that Appellant had failed to file a mandatory affidavit of his prior civil actions and had an adequate remedy in the ordinary course of the law. The Supreme Court affirmed, holding that relief in mandamus was not available because Petitioner had an adequate remedy in the ordinary course of the law. View "State ex rel. Steiner v. Rinfret" on Justia Law

The Supreme Court affirmed the judgment of the trial court determining that Defendant's use of its barn on property it owned in Litchfield Township was utilized primarily for the production of wine made from grapes and for the sale of wine produced therein in order for the use of the barn to be exempt from zoning regulation pursuant to Ohio Rev. Code 519.212(A), holding that the trial court did not err.Defendant owned a barn on land designated as residential. The Litchfield Township Board of Trustees sought to enjoin Defendant from using its land for weddings and other social gatherings. On remand, the trial court determined that the barn met the "vinting and selling wine" exemption under section 519.21(A). The court of appeals affirmed. The Supreme Court affirmed, holding that the trial court properly applied the primary-use test under section 519.21(A) in determining that the primary use of the barn was for vinting and selling wine. View "Litchfield Township Board of Trustees v. Forever Blueberry Barn, LLC" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's request for a writ of prohibition and/or mandamus against Montgomery County Court of Common Pleas Judge E. Gerald Parker Jr., holding that the court of appeals correctly determined that Appellant's claim was barred by res judicata.Appellant sought a petition for writ of prohibition and/or mandamus against Judge Erik Blaine, the successor to the judge who sentenced Appellant, alleging that the sentencing court patently and unambiguously lacked jurisdiction to sentence him. Judge Parker, who had succeeded Judge Blaine, subsequently filed a motion for summary judgment. The court of appeals granted summary judgment for Judge Parker, concluding that Appellant failed to demonstrate that the sentencing court patently and unambiguously lacked jurisdiction or that he lacked an adequate remedy at law and that res judicata barred Appellant's claim. The Supreme Court affirmed, holding that Appellant's claim was barred by res judicata. View "State ex rel. Kendrick v. Parker" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against the Trumbull Correctional Institution and Julie Loomis, the assistant to the warden (collectively, TCI), holding that the appellate court erred in dismissing Appellant's public-records mandamus complaint.While incarcerated at the Trumbull Correction Institution, Appellant submitted a handwritten public-records request to TCI seeking legal-mailroom logs and the dates and times that the institutional inspector made rounds in the housing units for certain periods. Loomis provided copies of the portions of the requested legal-mailroom logs in which Appellant's name appeared but none of the remaining records. Appellant filed a complaint seeking to compel TCI to provide him with the rest of his requested records. The court of appeals dismissed the complaint, determining that the complaint was moot because Appellant had already received all the requested records to which he was entitled. The Supreme Court reversed, holding that where TCI provided no evidence demonstrating that it complied with the second part of Appellant's records request, the court of appeals erred when it concluded that Appellant's claim was moot. View "State ex rel. Parker Bey v. Loomis" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against former Lorain County Court of Common Pleas Judge Thomas W. Janas, holding that Appellant's complaint sufficiently alleged that the judge patently and unambiguously lacked jurisdiction to change Appellant's sentence after the sentence had been affirmed on appeal.In 1994, following Appellant's conviction for aggravated murder, the trial court sentenced Appellant to life in prison with parole eligibility after twenty years. In 2018, the Adult Parole Authority informed Appellant that the trial court had issued a nunc pro tunc entry in 1999 stating that Appellant's sentence for aggravated murder was twenty full years to life. In 2019, Appellant filed a complaint for a writ of mandamus arguing that the trial court patently and unambiguously lacked jurisdiction to issue the nunc pro tunc entry after the court of appeals had affirmed his sentence. The court of appeals dismissed the complaint. The Supreme Court reversed, holding that Appellant's complaint stated a meritorious claim that the trial court patently and unambiguously lacked jurisdiction to change his sentence after his sentence had been affirmed on appeal. View "State ex rel. Davis v. Janas" on Justia Law

The Supreme Court vacated the adult portion of A.W.'s juvenile disposition, holding that because the juvenile court's order invoking the adult sentence under the serious youthful offender (SYO) specification was not journalized until A.W. turned twenty-one years old, the juvenile court lacked subject matter jurisdiction when it entered the adult portion of the sentence.At the age of seventeen, A.W. committed an act which, if committed by an adult, would constitute the offense of rape. The count was later amended to include an SYO specification. The court placed A.W. in custody until he would turn twenty-one years old and found A.W. to be an SYO. As A.W. neared his twenty-first birthday the State filed a motion to invoke the adult portion of his SYO sentence on the grounds that he had failed to complete "mandatory" sex-offender treatment. After a hearing, the juvenile court terminated the juvenile disposition and invoked the adult sentence. The court of appeals affirmed. The Supreme Court reversed, holding that although the juvenile court issued its order invoking the adult sentence while A.W. was twenty years old, the clerk of the court did not enter that order upon the journal until after A.W. turned twenty-one years old, depriving the juvenile court of subject matter jurisdiction. View "In re A.W." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court placing Mother's child in the permanent custody of the Portage County Department of Job and Family Services (the agency), holding that because the child was in the temporary custody of the agency for twelve or more months of a consecutive twenty-two-month period, the agency was entitled to seek permanent custody.After the was found to be a dependent child the agency was given temporary custody. Later, the agency filed a motion for permanent custody of the child. After a hearing, court placed the child in the permanent custody of the agency. The court of appeals affirmed. At issue was whether, under section 2151.414(B)(1)(d), an agency may seek permanent custody of a child only if the child has been in the temporary custody of the agency for twelve or more months of a consecutive twenty-two-month period. The Supreme Court answered in the negative, holding that permanent custody may be granted to an agency if the child has been in the temporary custody of one or more public children services agencies for twelve or more months of a consecutive twenty-two-month permanent and permanent custody is in the best interest of the child. View "In re N.M.P." on Justia Law

The Supreme Court reversed the judgment of the court of appeals granting Christina Neitzelt's request for a writ of mandamus ordering the Industrial Commission to vacate its order disallowing an L4-L5 disc herniation as an allowed condition in Appellant's workers' compensation claim, holding that under the some evidence standard, the Commission did not abuse its discretion.After Neitzelt had back surgery the Commission granted her employer's request to disallow the L4-L5 disc herniation from Neitzelt's claim based on evidence arising from the surgery. The court of appeals concluded that the Commission's exercise of its continuing jurisdiction was untimely and therefore improper. The Supreme Court reversed, holding that some evidence before the Commission supported its conclusion that Neitzelt's employer established both new or changed circumstances and a mistake in fact. View "State ex rel. Neitzelt v. Industrial Commission" on Justia Law

The Supreme Court reversed the judgment of the court of appeals finding that Defendant's conviction was against the manifest weight of the evidence and reducing her conviction to a lesser included offense rather than ordering a new trial, holding that a new trial is the appropriate remedy when a reviewing court determines that a criminal conviction is against the manifest weight of the evidence.After a bench trial, Defendant was found guilty of assaulting a peace officer. On appeal, the court of appeals determined that Defendant's conviction was against the manifest weight of the evidence, but rather than ordering a new trial, the court of appeals modified the judgment to reduce the conviction to the lesser included offense of disorderly conduct. The Supreme Court reversed, holding that the court of appeals erred by not adhering precedent dictating that a new trial is the appropriate remedy when a reviewing court determines that a criminal conviction is against the manifest weight of the evidence. View "State v. Fips" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for writs of mandamus and procedendo to compel the court of common pleas judge to issue a judgment of conviction that constitutes a final, appealable order, holding that Appellant had an adequate remedy at law.In 1993, Appellant was convicted of aggravated murder with a firearm specification and other offenses. The court of appeals reduced the aggravated murder conviction to a murder conviction. In 1995, on remand, the trial court entered a modified judgment. Appellant later filed a motion arguing that the modified judgment entry was not a final, appealable order because it did not comply with Crim.R. 32(C). The trial court denied the motion. The court of appeals dismissed the appeal. In 2015, the trial court issued a new judgment of conviction sua sponte. Appellant did not appeal from the new entry. In 2018, Appellant filed an action seeking writs of mandamus and procedendo, arguing that the 2015 judgment of conviction was not a final, appealable order. The court of appeals dismissed the petition, concluding that Appellant had an adequate remedy at law. The Supreme Court affirmed, holding that the court of appeals properly dismissed the petition. View "State ex rel. Bonner v. Serrott" on Justia Law