Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals upholding the sentence imposed on Defendant for violating the conditions of his community control, holding that Defendant's violation of the condition that he obey all orders of his supervising officer was not a "technical violation," and therefore, the 180-day cap on a prison sentence for a technical violation in Ohio Rev. Code 2929.15(B)(1)(c)(ii) did not apply.Defendant pled guilty to four drug charges and was sentenced to four years of community control. The community control included certain standard conditions that Defendant was alleged to have violated. The trial court found that Defendant's action violated three standard community-control conditions, revoked Defendant's community control, and imposed a thirty-four-month aggregate prison sentence. The court of appeals affirmed. On appeal, Defendant argued that the 180-day cap on prison sentences set forth in section 2929.15(B)(1)(c)(ii) applies to all community-control violations that are not felonies. The Supreme Court affirmed, holding (1) the plain language of the statute does not support Defendant's interpretation that all noncriminal violations constitute "technical violation[s]" under the statute; and (2) Defendant's violation of the second standard condition was not a "technical violation" under section 2929.15(B)(1)(c)(ii). View "State v. Nelson" on Justia Law

The Supreme Court denied Keontae Stuart's request for a writ of mandamus to compel Larry Greene, the public-records custodian for the Southern Ohio Correctional Facility, to provide Stuart with a document from his public-records request, holding that because Greene eventually did provide a redacted copy of the document to Stuart, this aspect of the case was moot.In his merit brief, Stuart did not challenge the propriety of the redactions but, instead, argued that he was entitled to statutory damages due to Greene's alleged failure to make the record available promptly. The Supreme Court denied Stuart's request for a writ of mandamus compelling the payment of statutory damages, holding that, as a pro se litigant, Stuart was ineligible for an award of attorney fees. The Court also granted Greene's request to keep the supplemental notice sealed to keep the information confidential. View "State ex rel. Stuart v. Greene" on Justia Law

The Supreme Court denied Jerone McDougald's original action for a writ of mandamus to compel Larry Greene, the administrative assistance for the warden at the Southern Ohio Correctional Facility, to produce two public records and denied McDougald's request for an award of court costs and for statutory damages, holding that McDougald's request for a writ of mandamus was moot and that McDougald was not entitled to statutory damages.After McDougald filed his complaint for a writ of mandamus, Greene provided both documents to McDougald. Therefore, the Supreme Court dismissed the mandamus claim seeking those documents. The Supreme Court also denied McDougald's request for an award of statutory damages, holding (1) because McDougald did not deliver his two public-record requests by one of the qualifying statutory delivery methods, he was not entitled to an award of statutory damages; and (2) McDougald was not entitled to an award of court costs. View "State ex rel. McDougald v. Greene" on Justia Law

The Supreme Court denied Petitioner's request for a writ of habeas corpus, holding that Petitioner's allegations did not challenge the jurisdiction of the trial court and were therefore not cognizable in habeas corpus.In 1991, Petitioner was convicted of aggravated burglary and felonious assault. At issue in this case was whether the sentencing statutes in effect in 1991 or the sentencing statutes in effect in 2016 governed Petitioner's sentence. While he was incarcerated, Petitioner filed a petition for a writ of habeas corpus, arguing that he was not sentenced for his 1991 convictions until 2016 when the trial court issued a new sentencing entry for the 1991 convictions, and that in 2016 the trial court should have sentenced him under the statutes that were in effect on that date. The Supreme Court denied relief, holding that Petitioner's claim of sentencing error was not jurisdictional and was not therefore cognizable in habeas corpus. View "McIntyre v. Hooks" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's action seeking a writ of prohibition for failure to state a claim, holding that Appellant possessed an adequate remedy at law.In 1989 and 1990 Appellant was convicted for murder, drug abuse, and assault. In 1993, Appellant filed a petition for postconviction relief from his 1989 convictions. In 1994, Judge Dale A. Crawford of the Franklin County Court of Common Pleas denied the petition. In 1995, Judge Crawford issued a nunc pro tunc entry restating his denial of postconviction relief. In 2018, Appellant filed his complaint seeking a writ of prohibition to invalidate the 1995 nunc pro tunc order. The court of appeals dismissed the action for failure to state a claim. The Supreme Court affirmed, holding that Appellant possessed an adequate remedy at law by appeal in 1994 or in 1995 from the judgments denying his petition for postconviction relief. View "State ex rel. Neguse v. McIntosh" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the trial court's denial of Defendant's motion to vacate and/or suspend court costs, holding that the court of appeals erred in concluding that the trial court must consider the defendant's present or future ability to pay court costs in making the discretionary determination of whether to waive, suspend or modify court costs.Defendant was convicted of two counts of murder and ordered to pay court costs. Defendant later moved to vacate and/or suspend the court costs on the grounds that he was indigent. The trial court denied the motion. The court of appeals reversed as to court costs, holding that the trial court abused its discretion by overruling Defendant's motion without considering his indigence and ability to pay. The Supreme Court reversed, holding that a trial court need not consider a defendant's present or future ability to pay when ruling on a motion to vacate, suspend, or modify court costs under Ohio Rev. Code 2947.23(C). View "State v. Taylor" on Justia Law

The Supreme Court denied the writ of mandamus sought by Relators compelling Tuscarawas County Job and Family Services (TCJFS) to produce copies of, or permit Relators to inspect, records pertaining to their childhood history with TCJFS, holding that TCJFS did not have a clear legal duty to allow Relators to inspect or copy the records they sought.Relators were sisters who spent portions of their childhoods in the Tuscarawas County foster care system. Relators believed that they experienced trauma while in foster care and that access to their TCJFS records would help them move forward with their lives. Relators commenced this mandamus action seeking to compel TCJFS to produce copies of, or permit Relators' access to, TCJFS records pertaining to them. The Supreme Court denied the writ, holding (1) the TCJFS director's good-cause finding did not create a legal duty requiring TCJFS to give Relators full access to all TCJFS records pertaining to them; (2) Ohio.Adm.Code 5101:2-33-21(H) did not impose a duty on TCJFS to disseminate any records to Relators; and (3) Relators failed to submit sufficient evidence supporting that there was good cause to override Ohio Rev. Code 5153.17's confidentiality requirement. View "State ex rel. Martin v. Tuscarawas County Job & Family Services" on Justia Law

The Supreme Court denied the writ of mandamus sought by a judge seeking to compel a county to pay for his outside legal counsel, holding that the judge was not entitled to compel the county to pay for his lawyer.In 2018, Greene County Probate Judge Thomas O'Diam issued two orders that sought to take control of a courtroom. The orders also sought to compel Greene County to pay for the legal expenses arising from the Greene County Board of Commissioners' failure to comply with the orders. After the Board filed a petition for a writ of prohibition attempting to stop Judge O'Diam's orders from taking effect Judge O'Diam filed the present mandamus action seeking to enforce his orders. The Supreme Court granted the writ of prohibition. At issue in this mandamus proceeding was whether Judge O'Diam was entitled to outside counsel at the County's expense when he did not use the process set forth in Ohio Rev. Code 309.09(A), 305.14(A), and 305.17. The Supreme Court denied the requested writ of mandamus, holding that Judge O'Diam did not follow the statutory process, and therefore, he was not entitled to have the County pay his attorney fees. View "State ex rel. O'Diam v. Greene County Board of Commissioners" on Justia Law

In this class action, the Supreme Court reversed the judgment of the court of appeals affirming the common pleas court's decision to certify the class, holding that the common pleas court lacked subject matter jurisdiction over the class action for the named and prospective class plaintiffs whose claims for recovery fell within the express language of Ohio Rev. Code 5160.37.The class action sought a declaratory judgment that former Ohio Rev. Code 5101.58 relating to Medicaid reimbursements is unconstitutional. The action further sought to recover all sums paid to the Ohio Department of Medicaid (Department) under section 5101.58. Plaintiff moved to certify as a class all persons who paid any amount to the Department pursuant to the statute from April 6, 2007 to the present. The trial court certified the class. The court of appeals affirmed. The Supreme Court reversed, holding (1) section 5160.37 now provides the sole remedy for Medicaid program participants to recover excessive reimbursement payments made to the Department on or after September 29, 2007; and (2) therefore, the common pleas court lacked jurisdiction over the claims asserted by Plaintiffs. View "Pivonka v. Corcoran" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting the city of Xenia's request for a writ of mandamus ordering the Greene County Board of Commissioners (the county) to approve the city's annexation petition, holding that the city's petition satisfied the conditions of Ohio Rev. Code 709.23(E).The proposed annexation in this case concerned approximately forty-five acres of land located between Central State University and Xenia. The county denied the petition, determining that the petition did not satisfy section 709.023(E)(1), (4), (5), or (7). Thereafter, the city filed an original action in the court of appeals requesting a writ of mandamus compelling the county to approve the petition. The court of appeals issued the writ. The Supreme Court affirmed, holding (1) a writ of mandamus is a proper vehicle to compel the county to grant the petition; and (2) the city's petition satisfied the conditions specified in section 709.023(E). View "State ex rel. Xenia v. Greene County Board of Commissioners" on Justia Law