Justia Ohio Supreme Court Opinion Summaries

In this expedited election case, the Supreme Court granted a writ of mandamus to compel the Plain Local School District Board of Education to forward to the Stark County Board of Elections a petition proposing the transfer of some of Plain Local School District's territory to Jackson Local School District, holding that the school board had a clear legal duty to forward the transfer petition to the board of elections.The petition sought to have a proposal to transfer the territory at issue placed on the March 17, 2020 primary election ballot. Under Ohio Rev. Code 3311.242(B)(2), the school board was required to certify the proposal to the board of elections by December 18, 2019. The school board stated that it would not act on the petition until there was a final determination of its claims in a previously filed lawsuit challenging the constitutionality of section 3311.242. Relators sought mandamus relief against the school board. The Supreme Court granted mandamus relief and ordered the school board to cause the board of elections to check the sufficiency of the signatures on the petition, holding that Relators established a clear legal right to the requested relief and a clear legal duty on the part of the school board to provide it. View "State ex rel. Dunn v. Plain Local School District Board of Education" on Justia Law

The Supreme Court reversed the judgment of the court of appeals and reinstated the trial court's judgment denying Defendant's motion to withdraw his guilty plea, holding that Defendant did not suffer a manifest injustice when the trial court failed to tell him during his Crim.R. 11 plea colloquy that he would be subject to mandatory prison sentences for his second-degree felony sexual battery convictions.Defendant pleaded guilty to three counts of second-degree felony sexual battery and other offenses. After a plea colloquy in which the trial court told Defendant that none of his prison sentences were mandatory the trial court accepted Defendant's guilty plea and imposed an agreed-upon sentence. Defendant later filed a postsentencing motion to withdraw his guilty plea, arguing that the trial court erred by imposing mandatory sentences without first telling him that they were mandatory. The trial court denied the motion. The court of appeals reversed, concluding that Defendant should be permitted to withdraw his guilty plea. The Supreme Court reversed, holding that the trial court's error in failing to tell Defendant that part of his sentence would be mandatory did not prejudice Defendant. View "State v. Straley" on Justia Law

The Supreme Court vacated the judgment of the court of appeals reversing the judgment of the trial court granting summary judgment in favor of WBNS-TV, Inc. and dismissing Plaintiffs' defamation claim, holding that the court of appeals applied an incorrect standard in determining whether the fault element of the defamation claim had been met.The Columbus Police Department sent an information sheet to WBNS describing the robbery of a hoverboard from an eight-year-old. A photograph accompanying the information sheet depicted three siblings as potential suspects. The police department later released a statement that the people in the photograph had not been involved in the robbery. The siblings and their mother filed a complaint against WBNS alleging defamation. The trial court granted summary judgment for WBNS, concluding that Plaintiffs could not prove an essential element - fault - of their defamation claim. The court of appeals reversed. The Supreme Court vacated the court of appeals' judgment and remanded the cause to the court of appeals, holding (1) the standard set forth in Landsdowne v. Beacon Journal Publishing Co., 512 N.E.2d 979 (Ohio 1987), was the appropriate standard to apply in this case; and (2) the court of appeals erred by not applying this standard. View "Anderson v. WBNS-TV, Inc." on Justia Law

The Supreme Court accepted the State's appeal from the decision of the court of appeals concluding that a prior designation as a dangerous dog is a prerequisite to its owner being prosecuted for failing to confine a dangerous dog in violation of of Ohio Rev. Code 955.22(D), holding that a prior designation of dangerousness pursuant to section 955.222 or otherwise is not a prerequisite to prosecution for failing to abide by the statute's dangerous dog laws.Defendant was convicted of failing to confine a dangerous dog. The court of appeals reversed, holding that a previous dangerous dog designation is a prerequisite to finding a violation of section 955.22(D). The Supreme Court affirmed, albeit on different grounds, holding (1) neither due process nor statutory language requires a prior dangerous dog designation before a defendant can be prosecuted for noncompliance with section 955.22's dangerous dog provisions; but (2) the State failed to meet its burden of offering sufficient evidence to sustain a conviction for failure to control a dangerous dog. View "State v. Jones" on Justia Law

The Supreme Court affirmed the decision of the court of appeals refusing to consider for the first time on appeal the State's argument that Defendant lacked Fourth Amendment standing to contest the admission of seized evidence, holding that when the State fails to dispute a defendant's standing in the trial court, it is foreclosed on appeal from attacking the trial court's judgment on these grounds.Defendant filed a motion to suppress, arguing that a detention violated his Fourth Amendment rights. The trial court granted the motion to suppress, concluding that the arresting officer lacked a reasonable, articulable suspicion of criminal activity at the time he detained Defendant. The State appealed, arguing that Defendant lacked standing to contest the admission of the evidence seized. The court of appeals affirmed. The Supreme Court affirmed, holding that where the State did not assert in the trial court that Defendant lacked Fourth Amendment standing to challenge his detention, the State was precluded from asserting that argument in its appeal from the judgment granting Defendant's motion to suppress. View "State v. Wintermeyer" on Justia Law

The Supreme Court dismissed this expedited election case in which the village of Hills and Dales sought a writ of mandamus to compel the Plain Local School District Board of Education to forward to the Stark County Board of Elections a petition proposing the transfer of some of the school district's territory to Jackson Local School District, holding that the village lacked standing.Specifically, the Court held that where Ohio Rev. Code 3311.242 authorizes only qualified electors to submit a transfer petition and does not confer rights upon municipal corporations, the village lacked authority to seek a writ of mandamus compelling the enforcement of Ohio Rev. Code 3311.242. View "State ex rel. Hills & Dales v. Plain Local School District Board of Education" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's judgment dismissing Plaintiffs' claims for quiet title and declaratory judgment based on their contention that an oil and gas lease had terminated by its terms due to lack of production, holding that the twenty-one-year limitations period in Ohio Rev. Code. 2305.04 applied.In their complaint Plaintiffs alleged that the well at issue did not produce any oil or gas from its inception until 1999 and that the well had been inoperative for enough time to terminate the lease. Defendants asserted a statute of limitations defense to Plaintiffs' claims. The trial court held that Plaintiffs had not presented any evidence to satisfy their burden of proving that the well was no longer profitable and that Plaintiffs' claims were subject to a fifteen-year statute of limitations. Plaintiffs appealed, arguing that the correct limitations period was the twenty-one-year period under Ohio Rev. Code 2305.04. The court of appeals rejected the argument and affirmed the trial court's summary judgment for Defendants. The Supreme Court reversed, holding that the twenty-one-year statute of limitations period applied and that evidence of lack of production prior to 1999 was not irrelevant. View "Browne v. Artex Oil Co." on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that two sentencing statutes - Ohio Rev. Code 2925.041(C)(1) and 2929.14(A)(3)(b) - are in conflict and applying the rule of lenity to determine that Ohio Rev. Code 2929.14(A)(3)(b) and its lesser maximum penalty applies to violations of section 2925.041(A) when the drug in question is methamphetamine and the defendant has committed certain prior offenses, holding that section 2925.041(C)(1) applied to the defendant in this case. Defendant was convicted of one count of illegal assembly or possession of chemicals for the manufacture of methamphetamine, in violation of 2925.041(A). The trial court determined that section 2925.041(C)(1) applied and sentenced Defendant to a five-year prison term. The court of appeals reversed Defendant's sentence, holding that section 2929.14(A)(3)(b), the less punitive sentencing statute, applied. The Supreme Court reversed, holding that when a defendant is charged with a violation of section 2925.041(A) when the drug in question is methamphetamine and the defendant has committed certain prior offenses, the mandatory five-year sentence prescribed by section 2925.041(C)(1) is a special provision that prevails as an exception to the general statute, section 2929.14(A)(3)(b). View "State v. Pribble" on Justia Law

In this appeal from a criminal judgment the Supreme Court reversed the court of appeals' decision vacating some of Defendant's consecutive sentences and rendering Defendant's second assignment of error moot, holding that State v. Marcum, 59 N.E.3d 1231 (Ohio 2016), has no application to consecutive sentencing cases that are governed by Ohio Rev. Code 2953.08(G)(2).Defendant pleaded guilty to multiple offenses stemming from her act of stealing thousands of items from nursing home residents. Defendant waived her right to appeal including, but not limited to, the grounds listed in section 2953.08. The trial court imposed prison terms and ordered Defendant to serve the felony sentences consecutively. The court of appeals reviewed Defendant's sentence under Ohio Rev. Code 2929.11 and 2929.12 based on its reading of Marcum and determined that, while Defendant's consecutive sentences were appropriate and warranted the aggregate sentence was excessive and disproportionate. The Supreme Court reversed, holding (1) the State forfeited its argument that Defendant waived her right to appeal her sentence when it did not raise the issue at the court of appeals; and (2) the court of appeals should have analyzed Defendant's consecutive sentences for compliance with Ohio Rev. Code 2929.14(C)(4). View "State v. Gwynne" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus, holding that the court of appeals properly dismissed the complaint on the grounds that it failed to state a claim for habeas relief and was barred by res judicata.Appellant was convicted of four counts of forgery and four counts of tampering with evidence. Appellant later filed a petition for a writ of habeas corpus, which the court of appeals dismissed. The Supreme Court affirmed, holding (1) none of Appellant's challenges to his convictions was cognizable in habeas corpus; and (2) the court of appeals also correctly determined that Appellant's claims were barred by res judicata. View "State ex rel. Kerr v. Turner" on Justia Law