Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals holding that a conviction for failure to register as a sex offender under Ohio Rev. Code 2950.04 does not violate a defendant's due-process and jury-trial rights guaranteed by the state and federal Constitutions when the duty to register arises from a juvenile court's delinquency adjudication, holding that such a conviction is not unconstitutional.Appellant was adjudicated delinquent as to what would have been two counts of fourth-degree felony gross sexual imposition if committed by an adult. Appellant was classified as a juvenile-offender registrant and tier I sex offender and was ordered to comply with statutory registration, notification-of-address-change, and verification duties for a period of ten years. Appellant was later convicted for violating a duty to register as a sex offender. On appeal, Appellant argued that his conviction was unconstitutional based on State v. Hand, 73 N.E.3d 448 (Ohio 2016). The court of appeals affirmed. The Supreme Court affirmed, holding (1) that Appellant's conviction for a violation of section 2950.04 for that arose from a juvenile adjudication did not violate Appellant's rights to a jury or due process under the Ohio Constitution and United States Constitution. View "State v. Buttery" on Justia Law

The Supreme Court dismissed as moot Victoria Ullmann's mandamus complaint seeking to compel Respondent, Columbus City Attorney Zach Klein, to comply with two public-records requests, granted Ullmann's motion for statutory damages, and denied her request for attorneys fees, holding that Ullmann was entitled to statutory damages because Klein failed timely to produce records responsive to Ullmann's public-records requests.At issue before the Supreme Court in Ullmann's mandamus action was whether Klein failed to respond to her public-records requests. In her merit brief, Ullmann stated that she had "finally gotten lots of the documents" she requested from Klein. The Supreme Court dismissed Ullmann's complaint against Klein as moot, holding that because Ullmann failed to identify what public records responsive to her requests remained undisclosed or show that the documents provided were unlawfully redacted, Ullmann was not entitled to a writ of mandamus. The Court further granted Ullmann an award of statutory damages in the amount of $1,000, denied her request for attorney fees, and denied her motions for in camera review of redacted documents Klein provided her and for oral argument. View "State ex rel. Ullmann v. Klein" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals ruling that Appellant's complaint for a writ of mandamus is barred by the doctrine of res judicata, holding that the court of appeals correctly applied res judicata to Appellant's claim.Appellant went into the office of the Plain Township zoning inspector to complain about a neighbor's trees, and the inspector told Appellant that the trees did not violate the zoning code. Appellant later filed a mandamus action seeking to compel the inspector and the Plain Township Board of Trustees to enforce the zoning provision against his neighbor. The court of appeals dismissed the complaint. Two years later, Appellant attempted to appeal the inspector's initial decision, but the board of zoning appeals dismissed the appeal as untimely. Appellant then filed a second mandamus action in the court of appeals seeking to compel the inspector to issue his initial decision in writing. The court of appeals held that res judicata barred the claim because Appellant could have asserted that claim in his first mandamus action. The Supreme Court affirmed, holding that the court of appeals correctly applied res judicata to Appellant's claim against the inspector in this case. View "State ex rel. Armatas v. Plain Township Board of Zoning Appeals" on Justia Law

The Supreme Court reversed the judgment of the court of appeals granting Appellant's petition for a writ of mandamus against Judge John W. Rudduck of the Clinton County Court of Common Pleas, holding that Appellant had an adequate remedy at law that precluded extraordinary relief.In 1993, Appellant was convicted of aggravated murder and other crimes. In 2019, Appellant filed a motion for a final appealable order in the court of common pleas, arguing that the trial court did not properly journalize his convictions in a single docket. Judge Rudduck denied the motion. Appellant then filed his petition for a writ of mandamus. The court of appeals granted the petition and ordered Judge Rudduck to file a nunc pro tunc entry to bring the judgment of conviction in Appellant's 1993 criminal case into compliance with Crim.R. 32(C). The Supreme Court reversed, holding that the court of appeals erred in granting a writ of mandamus because Appellant had an adequate appellate remedy in the ordinary course of law. View "State ex rel. Haynie v. Rudduck" on Justia Law

The Supreme Court realigned its precedent in cases involving the imposition of postrelease control with the traditional understanding of what constitutes a void judgment, holding that where a common pleas court has subject matter jurisdiction over the case and personal jurisdiction over the accused any error in the exercise of its jurisdiction in failing to properly impose postrelease control renders the judgment of conviction voidable, not void.Defendant pleaded guilty to robbery as a third-degree felony. The trial court sentenced Defendant to three years imprisonment and imposed a mandatory three-year term of postrelease control. The court, however, did not include the consequences of a violation of postrelease control in the sentencing entry as required by State v. Grimes, 85 N.E.3d 700 (Ohio 2017). Defendant later moved to vacate the postrelease control portion of his sentence, alleging it was void under Grimes. The trial court denied the motion. The court of appeals remanded the case to the trial court for further proceedings to correct the entry imposing postrelease control. The Supreme Court reversed, holding that when the sentencing court has jurisdiction to act, sentencing errors in the imposition of postrelease control render the sentence voidable, not void, and the sentence may be set aside if successfully challenged on direct appeal. View "State v. Harper" on Justia Law

The Supreme Court held that 2015 Am.Sub.H.B. No. 70 (H.B. 70) does not usurp the power of city school boards in violation of Ohio Const. art. VI, 3, and the bill received sufficient consideration for purposes of Ohio Const. art. II, 15(C).The purpose of H.B. 70 was to enact new sections within Ohio Rev. Code Chapter 3302 to authorize community schools and school districts to create community learning centers at schools where academic performance was low. After the bill was signed into law, Appellants moved for a declaratory judgment and permanent injunction, arguing that H.B. 70 was unconstitutional, as was the General Assembly's legislative process in enacting it. The trial court denied the motion for preliminary injunction and declaratory judgment, and the court of appeals affirmed. The Supreme Court affirmed, holding that the enactment of H.B. 70 violated neither the three-consideration rule articulated in Article II, Section 15(C) nor the right of voters to decide the number of members and the organization of the district board of education, as guaranteed by Article VI, Section 3. View "Youngstown City School District Board of Education v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus against the warden of the North Central Correctional Complex, holding that the complaint failed to state a cognizable claim in habeas corpus.Specifically, the Supreme Court held that the district court correctly found that Appellant's sentence was not void and correctly rejected Appellant's claim that the trial court lacked subject-matter jurisdiction. Further, the Supreme Court denied Appellant's motions for judicial notice, holding that the Court was precluded from granting judicial notice. View "State ex rel. Harris v. Turner" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that a new business would receive the prior business's "experience rating" for purposes of calculating the business's "unemployment tax," holding that because both businesses were not under substantially the same ownership, management, or control at the time the transfer occurred, the new business was not subject to the prior business's experience rating.Ohio employers pay an unemployment tax to support the workers' compensation system. The tax is based partly on an employer's experience rating, which is derived from the amount of unemployment benefits that have been paid to the employer's former employees. In this case, the new employer did not share common ownership, management, or control with the old employer on the date of the transfer. The new employer did, however, hire the old employer's management team. The court of appeals concluded that the new employer would receive the prior employer's experience rating. The Supreme Court reversed, holding (1) the language in Ohio Rev. Code 4141.24(G)(1) requires concurrent ownership, management, or control of both employers at the time that the business or trade is transferred; and (2) therefore, the new employer was not subject to the prior employer's experience rating. View "Delphi Automotive System, LLC v. Ohio Department of Job & Family Services" on Justia Law

The Supreme Court denied a writ of mandamus sought by Relator to compel Respondent, the public-records custodian at the Southern Ohio Correctional Facility (SOCF), to provide Relator with three public records and to pay Relator statutory damages and court costs associated with this litigation, holding that Relator was not entitled to either a writ of mandamus nor statutory damages.When Relator was an inmate at SOCF he submitted a public-records request to Respondent seeking three documents. Respondent provided one of the three documents. Relator then filed a complaint for a writ of mandamus seeking an order compelling Respondent to provide the two documents and to pay statutory damages and court costs associated with this litigation. The Supreme Court denied the writ of mandamus on the merits, holding that Respondent's response to Relator fully satisfied Respondent's obligations under Ohio Rev. Code 149.43, and therefore, Relator was not entitled a writ of mandamus, and there was no basis to award statutory damages. View "State ex rel. McDougald v. Greene" on Justia Law

In this insurance dispute, the Supreme Court affirmed the trial court's grant of summary judgment to Insurer, holding that specific language in the insurance policy was sufficient to warn Insured that misstatements as to warranties in her application for the policy rendered the policy void ab initio.Insurer submitted an application to Insured indicating that she was the only member of her household, and the application was incorporated into the policy under the policy's terms. Insured's, sister, however, was living with Insured when the sister struck a pedestrian while driving the car covered under the policy. Insured filed a complaint for declaratory judgment claiming that because of Insured's misstatements, the policy was void ab initio. The trial court agreed and granted summary judgment to Insurer. The Supreme Court affirmed, holding that the misstatement regarding the warranty in the application for the insurance policy rendered the policy void ab initio. View "Nationwide Mutual Fire Insurance Co. v. Pusser" on Justia Law