Justia Ohio Supreme Court Opinion Summaries

The Supreme Court denied the writ of mandamus sought by Andrew Frank to compel Ohio State University (OSU) to provide documents that Frank's attorney had requested in a public-records request, holding that OSU responded promptly and fully to the attorney's request and that Frank was not entitled to a writ of mandamus.The records in question were student records containing "personally identifiable information." The parties disputed whether the Family Education Rights and Privacy Act, 20 U.S.C. 1232g, applied to the requested records. The Supreme Court denied the writ of mandamus without reaching the issue, holding that OSU responded promptly and fully to the attorney's request and, therefore, Frank was not entitled to a writ of mandamus. View "State ex rel. Frank v. Ohio State University" on Justia Law

The Supreme Court granted a writ of prohibition to prevent the City of Toledo from conducting an administrative hearing to adjudicate Susan Magsig's liability for violating a municipal traffic ordinance, holding that Toledo had no jurisdiction to conduct its own quasi-judicial proceedings.Toledo's automated system generated a notice of liability for a speeding offense that Magsig allegedly committed. Magsig brought an action for a writ of prohibition to prevent Toledo from conducting the administrative hearing on the grounds that Ohio Rev. Code 1901.20(A)(1), as amended by 2019 Am.Sub.H.B. No. 62, vested exclusive jurisdiction in the municipal courts to adjudicate alleged noncriminal traffic-law violations. The Supreme Court granted the writ, holding that section 1901.20(A)(1) expressly vests exclusive jurisdiction over noncriminal traffic-law adjudications in the municipal courts. View "State ex rel. Magsig v. City of Toledo" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions on charges relating to the murder of Robert Williams, holding that there was sufficient evidence to support the convictions.Defendant was convicted and sentenced for aggravated murder, conspiracy, aggravated burglary, and kidnapping. At issue on appeal was whether there was sufficient evidence to support the jury's verdicts that Defendant, who did pull the trigger killing Williams, had conspired to murder Williams and had been complicit in the acts leading to his death. The Supreme Court concluded that the verdicts were based upon sufficient evidence, holding that the evidence of Defendant's involvement in the crimes associated with the killing of Williams was sufficient to find her guilty of the crimes. View "State v. McFarland" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the order of the court of common pleas, domestic relations division, ordering the release, subject to a protective order, of the mental-health records of Mother, holding that the physician-patient privilege did not shield the records from discovery.During the parties' divorce proceedings, both parties sought custody of their four children. During discovery, Father issued subpoenas for Mother's mental health records to various doctors and mental-health provisions. The trial court ordered that the subpoenaed records be submitted under seal to the court for an in camera determination of their relevance. After in camera review, the trial judge concluded that Mother's requests for child custody and spousal support put her physical and mental conditions at issue and waived the physician-patient privilege. The court then ordered the release of the mental-health records, subject to a protective order. The court of appeals affirmed. The Supreme Court affirmed, holding that while communications between a physician and patient are generally privileged, Mother's filing of this divorce action, with claims for child custody and spousal support, triggered the Ohio Rev. Code 2317.02(B)(1)(a)(iii) exception to the privilege. View "Torres Friedenberg v. Friedenberg" on Justia Law

The Supreme Court held that the enhanced penalty for unlawful sexual conduct with a minor does not apply when previous alleged criminal conduct predates the prior conviction, but rather, the enhancement only applies if, at the time of the offense, the offender has previously been convicted of a qualifying sex crime.In 2016, Defendant was convicted of one count of unlawful sexual conduct with a minor, in violation of Ohio Rev. Code 2907.04. In 2017, Defendant was again indicted for unlawful sexual conduct with a minor. The 2017 indictment alleged that the criminal behavior occurred before the 2016 conviction. The 2017 indictment sought to enhance the charges under section 2907.04(B)(4), which elevates the penalty for violating section 2907.04 if the defendant "previously has been convicted of" certain sex crimes. Defendant moved to dismiss the indictment, arguing that the enhancement does not apply when the alleged criminal conduct predates the prior conviction. The trial court granted the motion. The court of appeals reversed. The Supreme Court reversed, holding that, in order for the enhancement to apply, a defendant must have a qualifying conviction when he commits the charged offense. View "State v. Pendergrass" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against Muskingum County Court of Common Pleas Judge Mark Fleegle, holding that Appellant had an adequate remedy in the ordinary course of the law.Appellant, an inmate, filed a petition for a writ of mandamus seeking an order directing Judge Fleegle to "correct" his sentence. The court of appeals dismissed the petition for failure to state a claim. Appellant appealed, arguing that he met the elements for a writ of mandamus because his sentence was void and he had no adequate remedy at law. The Supreme Court affirmed, holding that Appellant had an adequate remedy by way of appeal to challenge any alleged sentencing error. View "State ex rel. King v. Fleegle" on Justia Law

The Supreme Court held that a civil-stalking protection order enjoining future online postings about Plaintiffs imposed an unconstitutional prior restraint on protected speech in violation of the First Amendment.Plaintiffs each filed a petition for a civil-stalking protection order (CSPO) against Defendant. The trial court granted the petitions and issued CSPOs that, among other things, prohibited Defendant from posting about Plaintiffs on any social media service, website, or discussion board. The court of appeals affirmed. The Supreme Court reversed the court of appeals' judgment to the extent that it upheld the trial court's CSPOs enjoining future postings about Plaintiffs or postings that express, imply or suggest that Plaintiffs were culpable in the deaths of their husbands, holding that this portion of the CSPOs did not survive strict scrutiny. View "Bey v. Rasawehr" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus sought by Appellant to compel Cuyahoga County Court of Common Pleas Judge Daniel Gaul to vacate his convictions, holding that the court of appeals was correct in concluding that Appellant's mandamus request failed as a matter of law.Appellant was found guilty of multiple rape and kidnapping counts and was sentenced to an aggregate prison term of fifty years to life. Appellant later filed a mandamus complaint to compel Judge Gaul to vacate his convictions, alleging that the trial court dismissed the first indictment against him on speedy-trial grounds and that he was protected against reindictment under the Double Jeopardy Clause. The Supreme Court affirmed, holding that Appellant's claims were barred by res judicata. View "State ex rel. Thomas v. Gaul" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against Summit County Court of Common Pleas Judge Alison M. Breaux, holding that Appellant was not entitled to relief on his propositions of law.Appellant was convicted of rape and domestic violence. The court of appeals affirmed. The Supreme Court summarily vacated the lower courts' judgments and remanded the case to the trial court for resentencing. After a new sentencing hearing the trial court issued a new sentencing entry. Appellant filed a motion to correct a void sentence arguing that the trial court had exceeded the scope of the Supreme Court's remand order when it purportedly imposed a harsher sentence than it had imposed in the original sentencing entry. The trial court denied the motion. Appellant subsequently sought a writ of mandamus to compel the trial court to conduct a new sentencing hearing. The court of appeals granted Judge Breaux's motion to dismiss. The Supreme Court affirmed, holding that Appellant's propositions of law either lacked merit or were not cognizable in mandamus. View "State ex rel. Simmons v. Breaux" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction for driving his vehicle fifteen miles per hour over the posted speed limit, holding that the results of a speed-measuring device using either radar or laser technology are admissible in court without expert testimony establishing, or the court taking judicial notice of, the reliability of the scientific principles underlying that technology.During Defendant's bench trial, the trial court admitted into evidence and considered the results of the laser speed-detection device that was used in calculating Defendant's excessive speed without establishing the reliability of the scientific principles underlying the device's technology. The trial court convicted Defendant without specifically taking judicial notice of the device's reliability. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the results of a radar speed-measuring device may be admitted into evidence without expert testimony establishing the reliability of the scientific principles underlying the technology or the court taking judicial notice of the scientific principles underlying that technology; and (2) the fact-finder is required to determine whether the evidence concerning the accuracy of the particular speed-measuring device and the qualifications of the person who used it are sufficient to support a conviction based on the device's results. View "City of Brook Park v. Rodojev" on Justia Law