Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against former Lorain County Court of Common Pleas Judge Thomas W. Janas, holding that Appellant's complaint sufficiently alleged that the judge patently and unambiguously lacked jurisdiction to change Appellant's sentence after the sentence had been affirmed on appeal.In 1994, following Appellant's conviction for aggravated murder, the trial court sentenced Appellant to life in prison with parole eligibility after twenty years. In 2018, the Adult Parole Authority informed Appellant that the trial court had issued a nunc pro tunc entry in 1999 stating that Appellant's sentence for aggravated murder was twenty full years to life. In 2019, Appellant filed a complaint for a writ of mandamus arguing that the trial court patently and unambiguously lacked jurisdiction to issue the nunc pro tunc entry after the court of appeals had affirmed his sentence. The court of appeals dismissed the complaint. The Supreme Court reversed, holding that Appellant's complaint stated a meritorious claim that the trial court patently and unambiguously lacked jurisdiction to change his sentence after his sentence had been affirmed on appeal. View "State ex rel. Davis v. Janas" on Justia Law

The Supreme Court vacated the adult portion of A.W.'s juvenile disposition, holding that because the juvenile court's order invoking the adult sentence under the serious youthful offender (SYO) specification was not journalized until A.W. turned twenty-one years old, the juvenile court lacked subject matter jurisdiction when it entered the adult portion of the sentence.At the age of seventeen, A.W. committed an act which, if committed by an adult, would constitute the offense of rape. The count was later amended to include an SYO specification. The court placed A.W. in custody until he would turn twenty-one years old and found A.W. to be an SYO. As A.W. neared his twenty-first birthday the State filed a motion to invoke the adult portion of his SYO sentence on the grounds that he had failed to complete "mandatory" sex-offender treatment. After a hearing, the juvenile court terminated the juvenile disposition and invoked the adult sentence. The court of appeals affirmed. The Supreme Court reversed, holding that although the juvenile court issued its order invoking the adult sentence while A.W. was twenty years old, the clerk of the court did not enter that order upon the journal until after A.W. turned twenty-one years old, depriving the juvenile court of subject matter jurisdiction. View "In re A.W." on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court placing Mother's child in the permanent custody of the Portage County Department of Job and Family Services (the agency), holding that because the child was in the temporary custody of the agency for twelve or more months of a consecutive twenty-two-month period, the agency was entitled to seek permanent custody.After the was found to be a dependent child the agency was given temporary custody. Later, the agency filed a motion for permanent custody of the child. After a hearing, court placed the child in the permanent custody of the agency. The court of appeals affirmed. At issue was whether, under section 2151.414(B)(1)(d), an agency may seek permanent custody of a child only if the child has been in the temporary custody of the agency for twelve or more months of a consecutive twenty-two-month period. The Supreme Court answered in the negative, holding that permanent custody may be granted to an agency if the child has been in the temporary custody of one or more public children services agencies for twelve or more months of a consecutive twenty-two-month permanent and permanent custody is in the best interest of the child. View "In re N.M.P." on Justia Law

The Supreme Court reversed the judgment of the court of appeals granting Christina Neitzelt's request for a writ of mandamus ordering the Industrial Commission to vacate its order disallowing an L4-L5 disc herniation as an allowed condition in Appellant's workers' compensation claim, holding that under the some evidence standard, the Commission did not abuse its discretion.After Neitzelt had back surgery the Commission granted her employer's request to disallow the L4-L5 disc herniation from Neitzelt's claim based on evidence arising from the surgery. The court of appeals concluded that the Commission's exercise of its continuing jurisdiction was untimely and therefore improper. The Supreme Court reversed, holding that some evidence before the Commission supported its conclusion that Neitzelt's employer established both new or changed circumstances and a mistake in fact. View "State ex rel. Neitzelt v. Industrial Commission" on Justia Law

The Supreme Court reversed the judgment of the court of appeals finding that Defendant's conviction was against the manifest weight of the evidence and reducing her conviction to a lesser included offense rather than ordering a new trial, holding that a new trial is the appropriate remedy when a reviewing court determines that a criminal conviction is against the manifest weight of the evidence.After a bench trial, Defendant was found guilty of assaulting a peace officer. On appeal, the court of appeals determined that Defendant's conviction was against the manifest weight of the evidence, but rather than ordering a new trial, the court of appeals modified the judgment to reduce the conviction to the lesser included offense of disorderly conduct. The Supreme Court reversed, holding that the court of appeals erred by not adhering precedent dictating that a new trial is the appropriate remedy when a reviewing court determines that a criminal conviction is against the manifest weight of the evidence. View "State v. Fips" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for writs of mandamus and procedendo to compel the court of common pleas judge to issue a judgment of conviction that constitutes a final, appealable order, holding that Appellant had an adequate remedy at law.In 1993, Appellant was convicted of aggravated murder with a firearm specification and other offenses. The court of appeals reduced the aggravated murder conviction to a murder conviction. In 1995, on remand, the trial court entered a modified judgment. Appellant later filed a motion arguing that the modified judgment entry was not a final, appealable order because it did not comply with Crim.R. 32(C). The trial court denied the motion. The court of appeals dismissed the appeal. In 2015, the trial court issued a new judgment of conviction sua sponte. Appellant did not appeal from the new entry. In 2018, Appellant filed an action seeking writs of mandamus and procedendo, arguing that the 2015 judgment of conviction was not a final, appealable order. The court of appeals dismissed the petition, concluding that Appellant had an adequate remedy at law. The Supreme Court affirmed, holding that the court of appeals properly dismissed the petition. View "State ex rel. Bonner v. Serrott" 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 was not entitled to relief on any of his three propositions of law.Appellant was convicted of an aggravated murder that he committed when he was a juvenile. In his habeas petition, Appellant argued that he was entitled to immediate release because the court of common pleas had lacked subject matter jurisdiction over his case for several reasons. The court of appeals dismissed the complaint, determining that the premise of Appellant's claim was false. The Supreme Court affirmed, holding that the court of appeals properly found that the judgment of conviction and sentence were not void ab initio for lack of subject matter jurisdiction. View "Stever v. Wainwright" on Justia Law

The Supreme Court granted a writ of mandamus sought by Katie O'Neill ordering the Athens County Board of Elections to declare that she was an eligible candidate for the Democratic nomination to the office of state representative for the 94th Ohio House District and to include in its official canvass of the primary election the votes cast for O'Neill, holding that the board abused its discretion by rejecting O'Neill's petition.On December 18, 2019, O'Neill filed her petition seeking to run for the Democratic nomination for the office of state representative for the 94th Ohio House District. The Board unanimously certified O'Neill's name to the primary ballot. Keith Monk filed a protest against O'Neill's candidacy. After a hearing, the Board voted in favor of the protest, concluding that O'Neill was not an eligible candidate for the nomination because she had not resided in the district for one year next preceding the November 3, 2020 general election and that the petition was invalid because O'Neill was not a registered voter in Athens County when she began circulating her part-petitions. The Supreme Court granted a writ of mandamus, holding that the Board abused its discretion and disregarded applicable law by upholding the protest to O'Neill's candidacy. View "State ex rel. O'Neill v. Athens County Board of Elections" on Justia Law

The Supreme Court granted in part a writ of mandamus sought by Ohioans for Secure and Fair Elections (Ohio-SAFE) seeking, among other things, to compel the Ohio Ballot Board to certify to the Attorney General that the Ohio-SAFE petition contained only one proposed constitutional amendment, holding that Ohio-SAFE had a clear legal right to certification of the proposed amendment as written and the Board had a clear legal duty to make that certification.Ohio-SAFE submitted to the Attorney General an initiative petition and summary, which would amend Ohio Const. art. V, section 1 to eliminate the thirty-day registration requirement to be eligible to vote. In addition, the proposed amendment would guarantee certain rights to every United States citizen who was or was eligible to become an elector in Ohio. The Secretary of State made a motion for the Board to find that the Ohio-SAFE amendment contained four separate proposals. The Board approved the amendment. The Supreme Court granted a writ of mandamus directing the Secretary of State to grant a writ of mandamus directing the Board to certify the Ohio-SAFE amendment as a single amendment, holding that mandamus should issue. View "State ex rel. Ohioans for Secure & Fair Elections v. LaRose" on Justia Law

The Supreme Court reversed the judgment of the court of appeals and reinstated Defendant's guilty pleas and convictions, reaffirming that trial courts in felony cases must strictly comply with the plea colloquy required by Crim.R. 11(C)(2)(c) and holding that a trial court strictly complies with Crim.R. 11(C)(2)(c) when it orally advises the defendant in a manner reasonably intelligible to the defendant that the plea waives the rights enumerated in the rule.At issue in this case was whether strict compliance with Crim.R. 11(C)(2)(c) requires that the plea colloquy include particular words. Defendant pleaded guilty to certain crimes. On appeal, Defendant argued that the pleas should be vacated because the trial court failed to ensure that he understood that by pleading guilty he was waiving the constitutional rights enumerated in Crim.R. 11(C)(2)(c). The court of appeals vacated Defendant's guilty pleas and reversed his convictions, concluding that the trial court failed to strictly comply with Crim.R. 11(C)(2) by failing to advise Defendant that he would waive his constitutional trial rights by pleading guilty. The Supreme Court reversed, holding that the trial court strictly complied with Crim.R. 11(C)(2)(c) by using easily understood words conveying to Defendant that he would be waiving certain constitutional rights if he were to plead guilty. View "State v. Miller" on Justia Law