Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals ruling that Appellant, a judgment creditor, did not have standing to bring a private cause of action against a city to enforce the city's obligations to its employees, holding that the right to indemnification set forth in Ohio Rev. Code 2744.07(A)(2) may be asserted only by an employee of a political subdivision.Appellant filed a complaint in federal district court asserted civil rights violations against the City of Cleveland and two of its police detectives. The court granted summary judgment for Cleveland but found that the detectives had violated Appellant's constitutional rights. The court entered a judgment against the detectives in the amount of $13,210,000. Appellant later filed this action against the City asserting, inter alia, claims of statutory indemnification under section 2744.07(B). The common pleas court concluded that the statute required the City to indemnify the officers and pay the judgment. The court of appeals reversed. The Supreme Court affirmed, holding that a judgment creditor may not proceed directly against a political subdivision under section 2744.07(B). View "Ayers v. Cleveland" on Justia Law

In this appeal concerning the trial court's award of $3,983,014 in attorney fees the Supreme Court reversed the judgment of the court of appeals affirming the award of attorney fees, holding that the "lodestar" reflected a reasonable fee based on the prevailing market rate for the services rendered by Appellees' attorneys, and therefore, the trial court's enhancement to the lodestar was in error.Appellees were awarded a jury verdict against Appellant for compensatory and punitive damages, treble damages, prejudgment interest, and litigation costs and expenses. In determining attorney fees, the trial court established a lodestar - the reasonable hourly rate multiplied by the number of hours worked - of $1,991,507. Then court then doubled the attorney fees due to the complexity and length of the case and the "highly favorable outcome" obtained by the attorneys. The court of appeals affirmed the award. The Supreme Court reversed, holding that Appellees' attorneys were reasonably compensated, so there should have been no enhancement to the lodestar. View "Phoenix Lighting Group, LLC v. Genlyte Thomas Group, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for violation of Ohio Rev. Code 4549.02(A)(1) and vacated the conviction, holding that the "registered number" of a vehicle, as used in the statute, is the license plate number associated with the vehicle.The trial court convicted Defendant with the charge of leaving the scene of a motor vehicle accident, concluding that Defendant failed to provide the registered number of his vehicle as required by section 4549.02(A)(1). The court of appeals affirmed on alternative grounds, holding that Defendant violated the statute by not providing the statutorily required identifying information to the police officer at the scene of the accident. The Supreme Court reversed, holding (1) when a driver subject to section 4549.02(A)(1) gives the information specified in that statute to the required recipients under section 4549.02(A)(1)(a) and (b), the driver does not violate section 4549.02(A)(1) by not providing that information to a police officer if the driver leaves the scene without knowledge that the police have been alerted of the accident; and (2) the registered number of a motor vehicle is the license plate number associated with the vehicle. View "State v. Bryant" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for writs of mandamus and procedendo against Ashtabula County Court Judge David A. Schroeder, holding that Appellant had an adequate remedy in the ordinary course of the law.Appellant filed a petition seeking a writ of mandamus ordering Judge Schroeder to grant his motion to vacate a trial court's judgment denying his motion for the return of his fine and court costs and seeking a writ of procedendo compelling Judge Schroeder to provide the clerk of courts with proper certification of the total amount of money to be returned to Appellant. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that because Appellant had an adequate remedy in the ordinary course of the law Appellant's request for extraordinary relief in mandamus and procedendo was barred. View "State ex rel. Davies v. Schroeder" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that the court of appeals correctly dismissed the petition because it did not comply with the statutory requirements of Ohio Rev. Code 2969.25(A).Appellant, who was seventeen years old at the time of the alleged offense, was convicted of three counts of murder and other crimes. Appellant was sentenced to an aggregate prison term of forty-one years to life. Appellant later filed a petition for a writ of habeas corpus claiming that the court of common pleas lacked subject matter jurisdiction because the juvenile court failed to make the required findings under Ohio Rev. Code 2152.12(A)(1)(a) before the transfer and challenging the constitutionality of the mandatory transfer procedures. The court of appeals dismissed Appellant's constitutional claims on procedural grounds. The Supreme Court affirmed, holding that Appellant's petition was fatally defective because he did not comply with Ohio Rev. Code 2969.25(A). View "Taylor v. Harris" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus and denying his complaint for a writ of mandamus, holding that the court of appeals did not err and declaring that Appellant a vexatious litigator.Appellant was convicted of voluntary manslaughter with a firearm specification. While on parole, Appellant was convicted of new offenses and received multiple definite prison sentences. In his habeas corpus petition Appellant claimed that the Bureau of Sentence Computation (BSC) miscalculated his sentence. Treating Appellant's motion as a request for mandamus relief, the magistrate concluded that the court of appeals lacked jurisdiction over Appellant's claim and that his claim was barred by res judicata. The court of appeals adopted the magistrate's recommendation, dismissed the habeas corpus portion of the complaint, and denied the writ of mandamus. Appellant appealed, and BSC requested that the Supreme Court declare Appellant a vexatious litigator. The Supreme Court affirmed and declared Appellant a vexatious litigator, holding that Appellant was not entitled to relief. View "State ex rel. Johnson v. Bureau of Sentence Computation" on Justia Law

The Supreme Court reversed the judgments of the court of appeals and remanded these cases to the juvenile court to enter orders of dismissal without prejudice, holding that Ohio Rev. Code 2151.35(B)(1) mandates the dismissal of a case if a juvenile court fails to conduct a dispositional hearing within ninety days of the filing of a complaint alleging that a child is abused, neglected or dependent.These cases involved two mothers and their children. Complaints were filed alleging the children to be abused and/or dependent. The mothers filed motions to dismiss arguing that section 2151.35(B)(1) required dismissal because the court had failed to hold its dispositional hearing within ninety days of the filing of the complaints. The juvenile court magistrates denied the motions. The magistrates found the children dependent and abused, and the juvenile courts adopted the magistrate's decisions. The court of appeals concluded that both mothers implicitly waived their right to a ninety-day disposition. The Supreme Court reversed, holding that because the magistrates did not hold disposition hearings within the ninety-day period the juvenile court erred by failing to enter orders of dismissal without prejudice. View "In re K.M." on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's complaint for a writ of mandamus against the Ohio Adult Parole Authority and its chairman (collectively, the APA), holding that the court of appeals correctly held that Appellant failed to preserve his claim alleging that the trial court failed to order that his sentence be served in a prison institution.Appellant filed a complaint for a writ of mandamus alleging that the APA incorrectly calculated his aggregate prison sentence. The court of appeals concluded that the APA correctly calculated Appellant's aggregate maximum term and rejected Appellant's contention that that APA had no authority to include the maximum term in its aggregate-sentence calculation because the sentencing entry did not specify that Appellant had to serve the sentence in a prison institution. The Supreme Court affirmed, Appellant failed to preserve his only claim on appeal. View "State ex rel. Newell v. Ohio Adult Parole Authority" on Justia Law

The Supreme Court reversed in part the judgment of the court of appeals affirming the judgment of the trial court convicting Defendant of four counts of rape of S.M., his step-daughter, and two counts of rape of J.M., his niece by marriage and six sexually-violent predator specifications, holding that a familial relationship is not a "mental or physical condition" for purposes of Ohio Rev. Code 2907.02(A)(1)(c).On appeal, Defendant argued that the State had not established that his victim's "ability to resist or consent [was] substantially impaired because of a mental or physical condition," Ohio Rev. Code 2907.02(A)(1)(c). The Supreme Court concluded that a familial relationship is not a mental or physical condition, and therefore, it was impossible for the State to prove beyond a reasonable doubt that Defendant violated section 2907.02(A)(1)(c) based on the theory that a familial relationship was the condition that caused the victims' substantial impairment. View "State v. Horn" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's second petition for a writ of habeas corpus against the warden of the Chillicothe Correctional Institution, holding that the court of appeals correctly granted the warden's motion to dismiss.In dismissing the petition, the court of appeals concluded that Appellant's claims were not cognizable in habeas corpus and that res judicata barred Appellant's successive habeas corpus petition. Appellant appealed the dismissal and also filed a motion to strike the warden's brief for lack of a valid certificate of service. The Supreme Court affirmed the judgment of the court of appeals and denied the motion to strike, holding that the court of appeals' analysis was correct in both respects and that Appellant presented no evidence to support his motion to strike. View "Green v. Shoop" on Justia Law