Justia Ohio Supreme Court Opinion Summaries
Taylor v. Harris
The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that the court of appeals correctly dismissed the petition because it did not comply with the statutory requirements of Ohio Rev. Code 2969.25(A).Appellant, who was seventeen years old at the time of the alleged offense, was convicted of three counts of murder and other crimes. Appellant was sentenced to an aggregate prison term of forty-one years to life. Appellant later filed a petition for a writ of habeas corpus claiming that the court of common pleas lacked subject matter jurisdiction because the juvenile court failed to make the required findings under Ohio Rev. Code 2152.12(A)(1)(a) before the transfer and challenging the constitutionality of the mandatory transfer procedures. The court of appeals dismissed Appellant's constitutional claims on procedural grounds. The Supreme Court affirmed, holding that Appellant's petition was fatally defective because he did not comply with Ohio Rev. Code 2969.25(A). View "Taylor v. Harris" on Justia Law
Posted in:
Criminal Law
State ex rel. Johnson v. Bureau of Sentence Computation
The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus and denying his complaint for a writ of mandamus, holding that the court of appeals did not err and declaring that Appellant a vexatious litigator.Appellant was convicted of voluntary manslaughter with a firearm specification. While on parole, Appellant was convicted of new offenses and received multiple definite prison sentences. In his habeas corpus petition Appellant claimed that the Bureau of Sentence Computation (BSC) miscalculated his sentence. Treating Appellant's motion as a request for mandamus relief, the magistrate concluded that the court of appeals lacked jurisdiction over Appellant's claim and that his claim was barred by res judicata. The court of appeals adopted the magistrate's recommendation, dismissed the habeas corpus portion of the complaint, and denied the writ of mandamus. Appellant appealed, and BSC requested that the Supreme Court declare Appellant a vexatious litigator. The Supreme Court affirmed and declared Appellant a vexatious litigator, holding that Appellant was not entitled to relief. View "State ex rel. Johnson v. Bureau of Sentence Computation" on Justia Law
Posted in:
Criminal Law
In re K.M.
The Supreme Court reversed the judgments of the court of appeals and remanded these cases to the juvenile court to enter orders of dismissal without prejudice, holding that Ohio Rev. Code 2151.35(B)(1) mandates the dismissal of a case if a juvenile court fails to conduct a dispositional hearing within ninety days of the filing of a complaint alleging that a child is abused, neglected or dependent.These cases involved two mothers and their children. Complaints were filed alleging the children to be abused and/or dependent. The mothers filed motions to dismiss arguing that section 2151.35(B)(1) required dismissal because the court had failed to hold its dispositional hearing within ninety days of the filing of the complaints. The juvenile court magistrates denied the motions. The magistrates found the children dependent and abused, and the juvenile courts adopted the magistrate's decisions. The court of appeals concluded that both mothers implicitly waived their right to a ninety-day disposition. The Supreme Court reversed, holding that because the magistrates did not hold disposition hearings within the ninety-day period the juvenile court erred by failing to enter orders of dismissal without prejudice. View "In re K.M." on Justia Law
Posted in:
Family Law
State ex rel. Newell v. Ohio Adult Parole Authority
The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's complaint for a writ of mandamus against the Ohio Adult Parole Authority and its chairman (collectively, the APA), holding that the court of appeals correctly held that Appellant failed to preserve his claim alleging that the trial court failed to order that his sentence be served in a prison institution.Appellant filed a complaint for a writ of mandamus alleging that the APA incorrectly calculated his aggregate prison sentence. The court of appeals concluded that the APA correctly calculated Appellant's aggregate maximum term and rejected Appellant's contention that that APA had no authority to include the maximum term in its aggregate-sentence calculation because the sentencing entry did not specify that Appellant had to serve the sentence in a prison institution. The Supreme Court affirmed, Appellant failed to preserve his only claim on appeal. View "State ex rel. Newell v. Ohio Adult Parole Authority" on Justia Law
Posted in:
Criminal Law
State v. Horn
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
Posted in:
Criminal Law
Green v. Shoop
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
Posted in:
Criminal Law
State ex rel. Holman v. Collins
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
Posted in:
Criminal Law
Vossman v. AirNet Systems, Inc.
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
Posted in:
Civil Procedure
Moore v. Wainwright
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
Posted in:
Juvenile Law
Columbus Bituminous Concrete Corp. v. Harrison Township Board of Zoning Appeals
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