Justia Ohio Supreme Court Opinion Summaries

The Supreme Court dismissed the Libertarian Party of Ohio's complaint asking the Supreme Court to invalidate Directive 2020-06 and establish procedures for completing the 2020 primary election, holding that subsequent actions by the secretary of state and the general assembly rendered those requests moot.On March 16, 2020 the director of the Ohio Department of Health issued an order closing polling places in Ohio to avoid the threat of exposure to COVID-19. That same night, the Secretary of State issued Directive 2020-06, which purported to extend absentee voting through June 1 and set June 2 as the date for in-person voting at polling places. On March 17, this expedited election case was filed seeking a writ of prohibition to invalidate the directive and establish procedures for completing the 2020 primary election. Thereafter, the General Assembly passed House Bill 197, an emergency act that voided Directive 2020-06 and established how the primary election will proceed. The governor signed House Bill 197 into law on March 27. The Supreme Court dismissed this cause, holding that the Libertarian Party's complaint was moot. View "State ex rel. Ohio Democratic Party v. LaRose" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing as moot Appellant's complaint for writs of mandamus and procedendo against Clark County Court of Common Pleas Judge Richard J. O'Neill, holding that the court of appeals correctly determined that Appellant's claims were moot.Appellant was found guilty in consolidated cases of murder with a firearm specification and attempted aggravated burglary. Appellant later filed under both case numbers a motion to vacate his postrelease control and a motion for a final, appealable order. The trial court denied the motion for a final, appealable order and granted in part the motion to vacate postrelease control, but the judgment entry did not refer to the motions that Appellant had filed in one of the two cases. Appellant filed a complaint for writs of mandamus and procedendo, arguing that Judge O'Neill had not yet ruled on his motions. Judge O'Neill filed a motion to dismiss, attaching a nunc pro tunc sentencing entry in which the judge effectively denied Defendant's motion to vacate his postrelease-control sentence in the second case. The court of appeals dismissed the claims as moot. The Supreme Court affirmed, holding that Appellant's claims were moot. View "State ex rel. Hibbler v. O'Neill" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus, holding that Appellant's claim was barred by res judicata.Appellant was convicted of aggravated murder with two firearm specifications. The indictment had contained a count of having a weapon while under disability (WUD), but the court's sentencing entry did not refer to the WUD charge. Appellant later filed a motion for a final, appealable order, arguing that the sentencing entry was void because it failed to dispose of the WUD charge. The trial court denied the motion. Appellant then filed a complaint for a writ of mandamus arguing that the sentencing entry did not dispose of the WUD charge and was not a final, appealable order. The court of appeals dismissed the complaint because Appellant had an adequate remedy in the ordinary course of the law and because Appellant's claim was barred by res judicata. The Supreme Court affirmed, holding that res judicata barred Appellant's mandamus claim because he had raised the same claim multiple times previously. View "State ex rel. Peoples v. Schneider" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals convicting Defendant of one count of murder in violation of Ohio Rev. Code 2903.02(A) and one count of murder in violation of Ohio Rev. Code 2903.02(B), holding that the trial court's admission of expert opinion testimony that was not set forth in a written report was harmless error.On appeal, Defendant argued that the state's failure to supply a written report providing the expert's opinions and scientific reasoning violated Crim.R. 16(K) and that the admission entitled him to a new trial. The court of appeals affirmed the convictions. The Supreme Court affirmed, holding (1) it is error to admit expert opinion testimony when the expert's opinion was not submitted in compliance with Crim.R. 16(K); but (2) in the instant case, the trial court's admission of testimony that went beyond the scope of the expert's written report was harmless error. View "State v. Boaston" on Justia Law

The Supreme Court granted Wood County Prosecuting Attorney Paul Dobson's request seeking a peremptory writ of prohibition against Judge Peter Handwork, who presided in two criminal cases finding Andrew Schuman guilty of seven felony counts and who later modified the judgment of sentence, holding that Judge Handwork patently and unambiguously lacked jurisdiction to issue the postjudgment orders.After entry of the judgment of sentence and Schuman's appeal was filed, Judge Handwork considered two motions filed by Schuman and issued two orders modifying the judgment of sentence. Dobson sought a writ of prohibition to vacate the post judgment orders and to prohibit any further exercise of jurisdiction by Judge Handwork. Because Judge Handwork did not file an answer, Dobson also filed a motion for default judgment. The Supreme Court granted the motion for default judgment and issued a peremptory writ of prohibition, holding that Handwork's absence of jurisdiction was patent and unambiguous. View "State ex rel. Dobson v. Handwork" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of prohibition to vacate judgments in two civil cases, holding that Appellant's claim was barred by res judicata.Appellant previously tried to vacate the civil judgments at issue in this case by filing a mandamus claim. The Supreme Court's dismissal of the mandamus complaint operated as an adjudication on the merits. The Supreme Court held that because Appellant's prior lawsuit attacking the validity of the same underlying judgments had been adjudicated on the merits, Appellant's current claim was barred by res judicata. View "State ex rel. Kerr v. Kelsey" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals ruling that Appellant, a judgment creditor, did not have standing to bring a private cause of action against a city to enforce the city's obligations to its employees, holding that the right to indemnification set forth in Ohio Rev. Code 2744.07(A)(2) may be asserted only by an employee of a political subdivision.Appellant filed a complaint in federal district court asserted civil rights violations against the City of Cleveland and two of its police detectives. The court granted summary judgment for Cleveland but found that the detectives had violated Appellant's constitutional rights. The court entered a judgment against the detectives in the amount of $13,210,000. Appellant later filed this action against the City asserting, inter alia, claims of statutory indemnification under section 2744.07(B). The common pleas court concluded that the statute required the City to indemnify the officers and pay the judgment. The court of appeals reversed. The Supreme Court affirmed, holding that a judgment creditor may not proceed directly against a political subdivision under section 2744.07(B). View "Ayers v. Cleveland" on Justia Law

In this appeal concerning the trial court's award of $3,983,014 in attorney fees the Supreme Court reversed the judgment of the court of appeals affirming the award of attorney fees, holding that the "lodestar" reflected a reasonable fee based on the prevailing market rate for the services rendered by Appellees' attorneys, and therefore, the trial court's enhancement to the lodestar was in error.Appellees were awarded a jury verdict against Appellant for compensatory and punitive damages, treble damages, prejudgment interest, and litigation costs and expenses. In determining attorney fees, the trial court established a lodestar - the reasonable hourly rate multiplied by the number of hours worked - of $1,991,507. Then court then doubled the attorney fees due to the complexity and length of the case and the "highly favorable outcome" obtained by the attorneys. The court of appeals affirmed the award. The Supreme Court reversed, holding that Appellees' attorneys were reasonably compensated, so there should have been no enhancement to the lodestar. View "Phoenix Lighting Group, LLC v. Genlyte Thomas Group, LLC" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for violation of Ohio Rev. Code 4549.02(A)(1) and vacated the conviction, holding that the "registered number" of a vehicle, as used in the statute, is the license plate number associated with the vehicle.The trial court convicted Defendant with the charge of leaving the scene of a motor vehicle accident, concluding that Defendant failed to provide the registered number of his vehicle as required by section 4549.02(A)(1). The court of appeals affirmed on alternative grounds, holding that Defendant violated the statute by not providing the statutorily required identifying information to the police officer at the scene of the accident. The Supreme Court reversed, holding (1) when a driver subject to section 4549.02(A)(1) gives the information specified in that statute to the required recipients under section 4549.02(A)(1)(a) and (b), the driver does not violate section 4549.02(A)(1) by not providing that information to a police officer if the driver leaves the scene without knowledge that the police have been alerted of the accident; and (2) the registered number of a motor vehicle is the license plate number associated with the vehicle. View "State v. Bryant" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for writs of mandamus and procedendo against Ashtabula County Court Judge David A. Schroeder, holding that Appellant had an adequate remedy in the ordinary course of the law.Appellant filed a petition seeking a writ of mandamus ordering Judge Schroeder to grant his motion to vacate a trial court's judgment denying his motion for the return of his fine and court costs and seeking a writ of procedendo compelling Judge Schroeder to provide the clerk of courts with proper certification of the total amount of money to be returned to Appellant. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that because Appellant had an adequate remedy in the ordinary course of the law Appellant's request for extraordinary relief in mandamus and procedendo was barred. View "State ex rel. Davies v. Schroeder" on Justia Law