Justia Ohio Supreme Court Opinion Summaries

The Supreme Court granted a writ of mandamus ordering the school board to certify a petition proposing the transfer of territory from one school district to another and certify the transfer proposal to the board of elections for placement on the ballot at the August 4 special election, holding that a writ of mandamus was warranted.Petitioner, a qualified elector in the territory proposed to be transferred, filed a mandamus complaint alleging that the school board failed to comply with its statutory obligations to promptly certify the petition and the proposal to the board of elections and that the school board's unwarranted delay caused the transfer proposal to miss the deadline for certification to the August 4 ballot. Petitioner also sought a writ ordering the board of elections to place the proposal on the August 4 ballot. The Supreme Court granted the writ as to the school board and denied it as to the elections board, holding (1) the school board had the opportunity to certify the proposal for placement on the August 4 special election ballot but declined to do so for reasons outside its authority; and (2) Petitioner's mandamus claim against the elections board was not ripe. View "State ex rel. Cook v. Bowling Green City Schools Board of Education" on Justia Law

The Supreme Court denied the writ of prohibition sought by a property owner who was the subject of a board of revision foreclosure seeking to invalidate the foreclosure adjudication, holding that the board of revision did not patently and unambiguously lack jurisdiction when it proceeded in the foreclosure action.The Cuyahoga Board of Revision (BOR) entered a judgment of foreclosure concerning real property owned by Elliott Feltner. More than a year later, Feltner filed this original action asserting multiple prohibition and mandamus claims against the BOR and others. The Supreme Court granted an alternative writ of prohibition as to two of the claims against the BOR and its members concerning whether the statutes under which the BOR proceeded violated the separation of powers doctrine or the due process clauses of the state and federal Constitutions. The Supreme Court then made a final determination denying the writ, holding (1) at the time of its judgment, the BOR acted with presumptively valid statutory authority and therefore did not patently and unambiguously lack jurisdiction to proceed; and (2) this Court therefore has no authority to undo the BOR's final judgment and need not consider the merit of Feltner's constitutional challenge. View "State ex rel. Feltner v. Cuyahoga County Board of Revision" on Justia Law

The Supreme Court dismissed this appeal brought by Appellant challenging the court of appeals' denial of his motion to certify a conflict, holding that this Court lacked the authority to review of the court of appeals' decision.Appellant was serving sentences for seven rape convictions when he filed a petition in the Second District Court of Appeals for a writ of prohibition and/or mandamus alleging that the trial judge in his case patently and unambiguously lacked jurisdiction to sentence him for one of the offenses. The Second District granted summary judgment for the judge. The Supreme Court affirmed. Appellant, in the meantime, filed a motion asking the Second District to certify that its judgment conflicts with other appellate decisions. The Second District denied the motion. The Supreme Court affirmed, noting that the Court lacks the authority to review a court of appeals' decision declining to certify the existence of a conflict. View "State ex rel. Kendrick v. Parker" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that it lacks original jurisdiction over declaratory judgment actions and dismissing the City of East Cleveland's petition for declaratory judgment sua sponte, holding that it is well settled that courts of appeals lack original jurisdiction over claims for declaratory judgment.The City of East Cleveland brought criminal charges against Randolph Dailey and Patricia Coleman, both of whom were sergeants in the Cleveland police department. A jury found Coleman not guilty. In an attempt to obtain review of the trial court's evidentiary rulings before Dailey went to trial, East Cleveland filed a petition for declaratory judgment. The court of appeals dismissed the case for lack of jurisdiction. The Supreme Court affirmed, holding that the court of appeals lacked original jurisdiction over the City's claim for declaratory judgment. View "State ex rel. City of East Cleveland v. Dailey" on Justia Law

The Supreme Court affirmed the judgment of the First District Court of Appeals holding that the trial court erred in allowing the state to strike a juror from the panel after the state had waived its final peremptory challenge, holding that while the appellate court incorrectly required Defendant to demonstrate that the error affected the outcome of the trial, the appellate court's error was itself harmless.On appeal, Defendant argued that the trial court's error in allowing the state to exercise a peremptory challenge out of sequence was structural in nature and therefore per se reversible. The First District held (1) the error was not a constitutional error and therefore could not amount to a structural error, and (2) the error was harmless because Defendant had failed to demonstrate that he had been prejudiced by it. The Supreme Court affirmed, but on different grounds, holding (1) the First District correctly concluded that the error was not structural; (2) the First District erred in failing to require the state to demonstrate that the error did not affect the outcome of the trial court proceedings; and (3) because allowing the state to exercise an additional peremptory strike did not affect the outcome of Defendant's trial, the appellate court's error was harmless. View "State v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the Sixth District Court of Appeals dismissing Appellant's petition seeking habeas relief, holding that the Sixth District correctly dismissed the petition.Appellant was convicted of multiple crimes and sentenced to an aggregate prison term of twenty-one years. After his convictions and sentences were affirmed on direct appeal Appellant filed a petition for a writ of habeas corpus asserting several grounds for relief. The Sixth District dismissed the petition, and the Supreme Court affirmed. The next year, Appellant filed a second petition seeking habeas relief. The Sixth District dismissed the petition, concluding that Appellant's claims were barred under the doctrine of res judicata and that Appellant had an adequate remedy at law. The Supreme Court affirmed, holding that res judicata barred Appellant's successive habeas corpus petition. View "Dixon v. Bowerman" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that a conviction for failure to register as a sex offender under Ohio Rev. Code 2950.04 does not violate a defendant's due-process and jury-trial rights guaranteed by the state and federal Constitutions when the duty to register arises from a juvenile court's delinquency adjudication, holding that such a conviction is not unconstitutional.Appellant was adjudicated delinquent as to what would have been two counts of fourth-degree felony gross sexual imposition if committed by an adult. Appellant was classified as a juvenile-offender registrant and tier I sex offender and was ordered to comply with statutory registration, notification-of-address-change, and verification duties for a period of ten years. Appellant was later convicted for violating a duty to register as a sex offender. On appeal, Appellant argued that his conviction was unconstitutional based on State v. Hand, 73 N.E.3d 448 (Ohio 2016). The court of appeals affirmed. The Supreme Court affirmed, holding (1) that Appellant's conviction for a violation of section 2950.04 for that arose from a juvenile adjudication did not violate Appellant's rights to a jury or due process under the Ohio Constitution and United States Constitution. View "State v. Buttery" on Justia Law

The Supreme Court dismissed as moot Victoria Ullmann's mandamus complaint seeking to compel Respondent, Columbus City Attorney Zach Klein, to comply with two public-records requests, granted Ullmann's motion for statutory damages, and denied her request for attorneys fees, holding that Ullmann was entitled to statutory damages because Klein failed timely to produce records responsive to Ullmann's public-records requests.At issue before the Supreme Court in Ullmann's mandamus action was whether Klein failed to respond to her public-records requests. In her merit brief, Ullmann stated that she had "finally gotten lots of the documents" she requested from Klein. The Supreme Court dismissed Ullmann's complaint against Klein as moot, holding that because Ullmann failed to identify what public records responsive to her requests remained undisclosed or show that the documents provided were unlawfully redacted, Ullmann was not entitled to a writ of mandamus. The Court further granted Ullmann an award of statutory damages in the amount of $1,000, denied her request for attorney fees, and denied her motions for in camera review of redacted documents Klein provided her and for oral argument. View "State ex rel. Ullmann v. Klein" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals ruling that Appellant's complaint for a writ of mandamus is barred by the doctrine of res judicata, holding that the court of appeals correctly applied res judicata to Appellant's claim.Appellant went into the office of the Plain Township zoning inspector to complain about a neighbor's trees, and the inspector told Appellant that the trees did not violate the zoning code. Appellant later filed a mandamus action seeking to compel the inspector and the Plain Township Board of Trustees to enforce the zoning provision against his neighbor. The court of appeals dismissed the complaint. Two years later, Appellant attempted to appeal the inspector's initial decision, but the board of zoning appeals dismissed the appeal as untimely. Appellant then filed a second mandamus action in the court of appeals seeking to compel the inspector to issue his initial decision in writing. The court of appeals held that res judicata barred the claim because Appellant could have asserted that claim in his first mandamus action. The Supreme Court affirmed, holding that the court of appeals correctly applied res judicata to Appellant's claim against the inspector in this case. View "State ex rel. Armatas v. Plain Township Board of Zoning Appeals" on Justia Law

The Supreme Court reversed the judgment of the court of appeals granting Appellant's petition for a writ of mandamus against Judge John W. Rudduck of the Clinton County Court of Common Pleas, holding that Appellant had an adequate remedy at law that precluded extraordinary relief.In 1993, Appellant was convicted of aggravated murder and other crimes. In 2019, Appellant filed a motion for a final appealable order in the court of common pleas, arguing that the trial court did not properly journalize his convictions in a single docket. Judge Rudduck denied the motion. Appellant then filed his petition for a writ of mandamus. The court of appeals granted the petition and ordered Judge Rudduck to file a nunc pro tunc entry to bring the judgment of conviction in Appellant's 1993 criminal case into compliance with Crim.R. 32(C). The Supreme Court reversed, holding that the court of appeals erred in granting a writ of mandamus because Appellant had an adequate appellate remedy in the ordinary course of law. View "State ex rel. Haynie v. Rudduck" on Justia Law