Justia Ohio Supreme Court Opinion Summaries

The Supreme Court realigned its precedent in cases involving the imposition of postrelease control with the traditional understanding of what constitutes a void judgment, holding that where a common pleas court has subject matter jurisdiction over the case and personal jurisdiction over the accused any error in the exercise of its jurisdiction in failing to properly impose postrelease control renders the judgment of conviction voidable, not void.Defendant pleaded guilty to robbery as a third-degree felony. The trial court sentenced Defendant to three years imprisonment and imposed a mandatory three-year term of postrelease control. The court, however, did not include the consequences of a violation of postrelease control in the sentencing entry as required by State v. Grimes, 85 N.E.3d 700 (Ohio 2017). Defendant later moved to vacate the postrelease control portion of his sentence, alleging it was void under Grimes. The trial court denied the motion. The court of appeals remanded the case to the trial court for further proceedings to correct the entry imposing postrelease control. The Supreme Court reversed, holding that when the sentencing court has jurisdiction to act, sentencing errors in the imposition of postrelease control render the sentence voidable, not void, and the sentence may be set aside if successfully challenged on direct appeal. View "State v. Harper" on Justia Law

The Supreme Court held that 2015 Am.Sub.H.B. No. 70 (H.B. 70) does not usurp the power of city school boards in violation of Ohio Const. art. VI, 3, and the bill received sufficient consideration for purposes of Ohio Const. art. II, 15(C).The purpose of H.B. 70 was to enact new sections within Ohio Rev. Code Chapter 3302 to authorize community schools and school districts to create community learning centers at schools where academic performance was low. After the bill was signed into law, Appellants moved for a declaratory judgment and permanent injunction, arguing that H.B. 70 was unconstitutional, as was the General Assembly's legislative process in enacting it. The trial court denied the motion for preliminary injunction and declaratory judgment, and the court of appeals affirmed. The Supreme Court affirmed, holding that the enactment of H.B. 70 violated neither the three-consideration rule articulated in Article II, Section 15(C) nor the right of voters to decide the number of members and the organization of the district board of education, as guaranteed by Article VI, Section 3. View "Youngstown City School District Board of Education v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus against the warden of the North Central Correctional Complex, holding that the complaint failed to state a cognizable claim in habeas corpus.Specifically, the Supreme Court held that the district court correctly found that Appellant's sentence was not void and correctly rejected Appellant's claim that the trial court lacked subject-matter jurisdiction. Further, the Supreme Court denied Appellant's motions for judicial notice, holding that the Court was precluded from granting judicial notice. View "State ex rel. Harris v. Turner" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that a new business would receive the prior business's "experience rating" for purposes of calculating the business's "unemployment tax," holding that because both businesses were not under substantially the same ownership, management, or control at the time the transfer occurred, the new business was not subject to the prior business's experience rating.Ohio employers pay an unemployment tax to support the workers' compensation system. The tax is based partly on an employer's experience rating, which is derived from the amount of unemployment benefits that have been paid to the employer's former employees. In this case, the new employer did not share common ownership, management, or control with the old employer on the date of the transfer. The new employer did, however, hire the old employer's management team. The court of appeals concluded that the new employer would receive the prior employer's experience rating. The Supreme Court reversed, holding (1) the language in Ohio Rev. Code 4141.24(G)(1) requires concurrent ownership, management, or control of both employers at the time that the business or trade is transferred; and (2) therefore, the new employer was not subject to the prior employer's experience rating. View "Delphi Automotive System, LLC v. Ohio Department of Job & Family Services" on Justia Law

The Supreme Court denied a writ of mandamus sought by Relator to compel Respondent, the public-records custodian at the Southern Ohio Correctional Facility (SOCF), to provide Relator with three public records and to pay Relator statutory damages and court costs associated with this litigation, holding that Relator was not entitled to either a writ of mandamus nor statutory damages.When Relator was an inmate at SOCF he submitted a public-records request to Respondent seeking three documents. Respondent provided one of the three documents. Relator then filed a complaint for a writ of mandamus seeking an order compelling Respondent to provide the two documents and to pay statutory damages and court costs associated with this litigation. The Supreme Court denied the writ of mandamus on the merits, holding that Respondent's response to Relator fully satisfied Respondent's obligations under Ohio Rev. Code 149.43, and therefore, Relator was not entitled a writ of mandamus, and there was no basis to award statutory damages. View "State ex rel. McDougald v. Greene" on Justia Law

In this insurance dispute, the Supreme Court affirmed the trial court's grant of summary judgment to Insurer, holding that specific language in the insurance policy was sufficient to warn Insured that misstatements as to warranties in her application for the policy rendered the policy void ab initio.Insurer submitted an application to Insured indicating that she was the only member of her household, and the application was incorporated into the policy under the policy's terms. Insured's, sister, however, was living with Insured when the sister struck a pedestrian while driving the car covered under the policy. Insured filed a complaint for declaratory judgment claiming that because of Insured's misstatements, the policy was void ab initio. The trial court agreed and granted summary judgment to Insurer. The Supreme Court affirmed, holding that the misstatement regarding the warranty in the application for the insurance policy rendered the policy void ab initio. View "Nationwide Mutual Fire Insurance Co. v. Pusser" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals denying Appellant's complaint for a writ of mandamus to compel the Cuyahoga County Clerk of Courts to produce various court records and denying the clerk's request that Appellant be declared a vexatious litigator, holding that the court of appeals erred in denying Appellant's complaint on the grounds that he did not invoke the Rules of Superintendence as the basis for his request.Appellant sought copies of journal entries from his criminal case and a copy of the clerk of courts' records-retention schedule. The clerk largely denied the request. Appellant then filed a complaint for a writ of mandamus. The court of appeals denied Appellant's request for mandamus relief, concluding that the clerk had no clear legal duty to provide the requested records. The Supreme Court reversed, holding (1) this action to compel the production of journal entries from a 1995 case was properly brought under the Public Records Act; and (2) this Court declines to impose sanctions on Appellant or to declare him a vexatious litigator. View "State ex rel. Parker Bey v. Byrd" on Justia Law

The Supreme Court reversed the judgment of the court of appeals vacating Defendant's conviction and sentence and reinstated the trial court's acceptance of Defendant's plea of no contest to sexual battery, holding that the trial court did not completely fail to comply with Crim.R.11(C)(2)(a), and there was nothing in the record to support a conclusion that Defendant would not have entered his plea had the trial court been more detailed in its explanation. On appeal, Defendant sought to vacate his plea of no contest, arguing that his plea was invalid because the trial court erred by not explaining more fully the obligations and restrictions that went with his status as a sex offender, in violation of Crim. R. 11(C)(2)(a). The court of appeals vacated the conviction without requiring Defendant to show prejudice, concluding that the trial court had completely failed to comply with Crim. R. 11(C)(2)(a). The Supreme Court reversed, holding (1) the trial court did not completely failed to comply with Crim R. 11(C)(2)(a)'s maximum-penalty-advisement requirement; and (2) because Defendant did not establish prejudice, he was not entitled to have his no-contest plea vacated for a failure to comply with Crim.R. 11(C). View "State v. Dangler" on Justia Law

The Supreme Court accepted a state-law question certified to it by the United States District Court for the Northern District of Ohio, Eastern Division and answered that an insured is not permitted to seek full and complete indemnity under a single policy providing coverage for "those sums" that the insured becomes legally obligated to pay because of property damage that takes place during the policy period when the property damage occurred over multiple policy periods.Insured sued Insurer seeking an order requiring Insurer to pay all defense costs incurred in defending the underlying lawsuit and the amounts Insured paid to settle the action. Insurer filed a counterclaim seeking a declaration that Insured was not entitled to allocate all defense costs and indemnity to a single policy period when multiple policies and corresponding policy periods were triggered. At issue was whether contract language providing coverage for "those sums" should be treated like contract language providing coverage for "all sums." The Supreme Court answered the question of state law as set forth above but cautioned against using the answer as a blanket rule applicable to all policies with "those sums" language. View "Lubrizol Advanced Materials, Inc. v. National Union Fire Insurance Co. of Pittsburgh, Pennsylvania" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's original action seeking a writ of procedendo and/or mandamus to compel Hamilton County Court of Common Pleas Judge Melba Marsh to issue a corrected sentencing entry, holding that the court of appeals correctly dismissed the petition as moot.Appellant was convicted of murder with a repeat-violent-offender specification. Appellant later asked the trial court to correct his sentence, arguing that he had improperly been sentenced to postrelease control. On remand, Judge Marsh vacated the postrelease-control sentence. Appellant appealed that order. The court of appeals noted that the trial court had not set forth all the information required under Crim.R. 32(C) in a single document and dismissed the appeal for lack of a final, appealable order. Appellant then filed this original action seeking to compel Judge Marsh to issue a corrected sentencing entry that constitutes a final, appealable order. Judge Marsh issued a nunc pro tunc sentencing entry that constituted a final, appealable order. The court of appeals then dismissed the petition as moot. The Supreme Court affirmed, holding that because Judge Marsh performed the act Appellant requested, the court of appeals dismissed the petition as moot. View "State ex rel. Roberts v. Marsh" on Justia Law