Justia Ohio Supreme Court Opinion Summaries

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

The Supreme Court affirmed the judgment of the court of appeals granting summary judgment to the warden of the Pickaway Correctional Institutional and dismissing Appellant's complaint for a writ of habeas corpus, holding that the court of appeals correctly granted summary judgment to the warden and dismissed Appellant's complaint for a writ of habeas corpus.Appellant, an inmate, filed a complaint for writ of habeas corpus asking the court to order his release from prison. In his complaint, Appellant challenged the actions of the Adult Parole Authority and alleged that because he had not been considered for parole since the completion of his sentence the warden was unlawfully restraining him. The court of appeals granted summary judgment for the warden. The Supreme Court affirmed, holding that Appellant's arguments rested on his mistaken belief that his sentence expired upon the completion of his minimum sentence and that Appellant's complaint for a writ of habeas corpus was correctly dismissed. View "State ex rel. Holman v. Collins" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court awarding Appellee costs to recover the cost of procuring deposition transcripts after an discrimination lawsuit was resolved on summary judgment, holding that Ohio Rev. Code 2303.21 does not provide statutory authority for a party to recover the cost of deposition transcripts used in support of a motion for summary judgment.Appellant sued Appellee for age discrimination. Over the course of litigation the parties took five depositions. Appellee filed a motion for summary judgment citing to the transcripts of the depositions in support of its motion. The trial court granted the motion for summary judgment. Thereafter, Appellee moved to recover the cost of procuring the deposition transcripts pursuant to section 2303.21. The trial court granted the motion. The Supreme Court reversed, holding that the statute does not allow the expense of procuring deposition transcripts to be taxed as a cost. View "Vossman v. AirNet Systems, Inc." 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 Appellant's petition was barred by the doctrine of res judicata.At the time he was a seventeen-year-old juvenile, Appellant was subjected to mandatory bindover to adult court regarding several charges. Appellant later pleaded guilty to murder with a firearm specification. The court of appeals erred, rejecting Appellant's argument that he had been entitled to an amenability hearing in the juvenile court before his case could be transferred to the adult court. Appellant later filed a petition for a writ of habeas corpus arguing that he was entitled to release because the juvenile court failed to conduct an amenability hearing and make the required findings to transfer his case to the adult court. The court of appeals dismissed the habeas petition. The Supreme Court affirmed, holding that because Appellant's petition again challenged the validity of his bindover proceedings his petition was barred by the doctrine of res judicata. View "Moore v. Wainwright" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the court of common pleas affirming the decision of the Harrison Township Board of Zoning Appeals (BZA) denying Appellants' request seeking approval to engage in sand-and-gravel mining, holding that the BZA erred in denying the request.Appellants filed an application for a conditional use permit to conduct sand-and-gravel mining. The BZA denied the application based on general conditions applicable to all conditional uses set forth in a Harrison Township zoning resolution. The court of common pleas and court of appeals affirmed. The Supreme Court reversed, holding that a general standard that does not relate to public health or safety may not be applied to deny an application to conduct mining as a conditional use. View "Columbus Bituminous Concrete Corp. v. Harrison Township Board of Zoning Appeals" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's complaint for a writ of mandamus to compel a common pleas court judge to enforce the terms of an agreement the county prosecutor had reached with Appellant's wife to secure her testimony against Appellant, holding that the court of appeals did not err.The court of appeals granted the judge's motion for summary judgment, holding that Appellant was not entitled to mandamus relief because he had an adequate remedy at law and because his claim was barred by the doctrine of res judicata. The Supreme Court affirmed, holding that the court of appeals correctly found that Appellant had a plain and adequate remedy and law and that Appellant's claim was barred by the doctrine of res judicata. View "State ex rel. Phelps v. McClelland" on Justia Law

The Supreme Court held in this criminal case that the trial court has the ability to resentence de novo a defendant on a specific count after the sentence related to that count has been vacated on direct appeal and the defendant has been confined for the length of the original prison term that had been attached to that count.Defendant was found guilty of five charges. The court of appeals reversed Defendant's conviction on Count Two and modified two other convictions to reflect lower degrees of the offenses. Upon remand from the Supreme Court, the court of appeals reinstated Count Two but reduced the degree level of the offense. On remand, the trial court resentenced Defendant on Count Two, Count Three, and Count Five. The aggregate sentence after the remand was the same as Defendant's original aggregate sentence. The court of appeal reversed, holding that, by the time Defendant was resentenced, she had already served the original prison term on Count Two and therefore count not be resentenced on Count Two even though she had not completed her sentence for Count Five. The Supreme Court reversed, holding that the trial court had the authority to resentence Defendant de novo on Count Two. View "State v. Christian" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against two court of common pleas judges, holding that the judges did not have a clear legal duty to provide the relief that Appellant sought.The judges in this case sentenced Appellant after he entered guilty pleas to criminal offenses and ordered him to pay court costs. Appellant filed this petition for a writ of mandamus seeking to compel the judges to vacate their orders imposing court costs and to hold hearings on his ability to pay court costs under Ohio Rev. Code 2947.23. The court of appeals granted the judges' motion to dismiss. The Supreme Court affirmed, holding that Appellant did not have a clear legal right to receive the relief he sought and failed to establish that he lacked an adequate remedy at law by which to challenge the trial courts' determinations. View "State ex rel. Martin v. Russo" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions for multiple counts of drug trafficking, holding that the warrant issued by a Sandusky County judge that allowed Drug Enforcement Agency agents sitting in Toledo (Lucas County) to listen to cell-phone calls of an alleged drug trafficker who was based in Sandusky County was valid because the government properly obtained the interception warrant in the Sandusky County Common Pleas Court.On appeal, Defendant argued that the warrant was invalid because the calls were intercepted in Toledo when the agents listened to them, and therefore, the warrant was issued by a judge in the wrong county. The Supreme Court disagreed, holding (1) interception occurs both at the place where agents are listening and at the place where the phone is used and (2) Defendant's calls were intercepted - captured and redirected - by law enforcement in Sandusky County where Defendant used his cell phone to facilitate drug trafficking, and therefore, the interception warrant was properly obtained in Sandusky County. View "State v. Nettles" on Justia Law