Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's habeas corpus petition against the warden of the Richland Correctional Institution (RCI), holding that the court of appeals did not err in dismissing the petition for failure to attach all the relevant commitment papers, as required by Ohio Rev. Code 2725.04(D).Appellant, an inmate at RCI, filed a petition for a writ of habeas corpus alleging that the prison sentences he was serving had expired and that, therefore, he was entitled to immediate release. The warden filed a motion to dismiss Appellant's petition but did not raise the sufficiency of the commitment papers attached to the petition as grounds for dismissal or summary judgment. Nonetheless, the court of appeals dismissed the petition on the basis that Appellant had failed to comply with section 2725.04(D). The Supreme Court affirmed, holding that, by failing to attach all the relevant commitment papers to his petition, Appellant did not comply with section 2725.04(D). View "State ex rel. Miller v. May" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying as moot a complaint for a writ of mandamus filed by the Municipal Construction Equipment Operators' Labor Council (the union) seeking to compel the city of Cleveland and its Civil Service Commission (collectively, Cleveland) to release public records relating to a job posting, holding that because the requested records were provided, the mandamus claim was moot.The court of appeals concluded that Cleveland had produced all records responsive to the union's request and denied the mandamus action as moot. Further, the court ordered each side to pay its own costs. The Supreme Court affirmed, holding (1) the union did not establish that Cleveland failed to comply with its duties under Ohio Rev. Code 149.43(B)(7)(a) or 149.43(B)(6); and (2) the union did not establish that Cleveland failed to promptly release records in violation of Ohio Rev. Code 149.43(B)(1). View "State ex rel. Municipal Construction Equipment Operators' Labor Council v. City of Cleveland" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that B.E.B. Properties reserved the right to receive future rental payments for leased land underneath a cell tower when it conveyed the property, holding that the deed did not contain such a reservation.B.E.B. Properties leased a portion of commercial property it owned to a cellular telephone company, and a cellular tower was erected on the site. B.E.B. subsequently sold the property to Keith Baker and Joseph Cyvas. Thereafter, two of the general partners in B.E.B. sold their interests in the partnership to Bruce and Sheila Bird, who believed this transaction included the assignment of the right to receive rental payments for the tower. When LRC Realty, Inc. acquired the property it sought a declaratory judgment that it was entitled to the annual rental payments. The trial court granted summary judgment for LRC Realty. The court of appeals reversed, concluding that the Birds were entitled to rental payments based on the language contained in the deed transferring the property from B.E.B. to Baker and Cyvas. The Supreme Court reversed, holding (1) absent a reservation in the deed conveying the property, the right to receive rents runs with the land; and (2) the deed here did not create such a reservation. View "LRC Realty, Inc. v. B.E.B. Properties" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals affirming the decision of the trial court revoking Defendant's community control and imposing the prison sentence that it had notified Defendant of at his initial sentencing hearing, holding that consecutive sentences were not properly imposed in this case.The court of appeals concluded (1) because the trial court had notified Defendant at his initial sentencing hearing of the specific prison terms that the court could impose if Defendant were to violate his community-control conditions, it was not required to repeat that notification before it imposed the prison terms at a second revocation hearing; and (2) the trial court had not been required to make consecutive-sentences findings required under Ohio Rev. Code 2929.14(c) when it revoked Defendant's community control and imposed consecutive prison terms. The Supreme Court reversed in part, holding (1) the trial court provided Defendant sufficient notice of the specific prison terms he could receive if his community control were to be revoked; but (2) a trial court must make statutorily required consecutive-sentences findings when it imposes consecutive sentences following the revocation of community control. View "State v. Howard" on Justia Law

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