Justia Ohio Supreme Court Opinion Summaries

The Supreme Court denied the writ of mandamus sought by Alex Penland, an inmate at the Toledo Correctional Institution (TCI), to compel Respondents to make available for inspection the contract under which a vendor was permitted to sell food to inmates confined in Ohio prisons, holding that Penland failed to establish that he was entitled to the writ.Penland brought his complaint against Respondents, the Ohio Department of Rehabilitation and Correction and Sonrisa Sehlmeyer, alleging that he made a public-records request to Sehlmeyer asking to review the contract but did not immediately receive a response to his request. When the subsequent inmate grievance process brought by Penland was not resolved to his satisfaction Penland filed this original action. The Supreme Court denied the writ, holding that Penland did not show that Respondents had a clear legal duty to deliver the contract to TCI for Penland's inspection at no cost to him. The Court further denied Penland's request for statutory damages because Penland did not deliver his request to Sehlmeyer by hand or by certified mail. View "State ex rel. Penland v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's denial of Corey Parker's petition for postconviction relief, holding Ohio Rev. Code 2953.23(A) does not vest a common pleas court with authority to grant relief on an untimely or successive petition for postconviction relief when that petition asserts a claim based on a new state or federal right recognized by the Ohio Supreme Court.In 2011, Parker pleaded guilty to criminal offenses. Parker later moved to vacate his mandatory sentence of eight years in prison, arguing that enhancing his adult sentence based on a prior juvenile-delinquency adjudication was unconstitutional. The court of appeals construed the motion to vacate as a petition for postconviction relief and reversed the trial court's denial of relief, concluding that Parker established that he was unavoidably presented from presenting his claim for relief until 2016. Implicit in the court's analysis was the determination that the statutory bar on untimely or successive petitions did not apply. The Supreme Court reversed, holding that none of the exceptions for an untimely or successive petition for postconviction relief applied in this case. View "State v. Parker" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Appellant's petition for a writ of habeas corpus against the warden of the Lebanon Correctional Institution, holding that the court of appeals correctly denied the writ of habeas corpus.Appellant was convicted of the rape and sexual battery of his wife's granddaughter. Appellant later filed a petition for a writ of habeas corpus alleging that his convictions were void for lack of subject-matter jurisdiction. The court of appeals determined that Appellant's claims were barred by res judicata and denied the writ on that basis. The Supreme Court affirmed, holding that Appellant was not entitled to habeas corpus relief. View "State ex rel. Whitt v. Harris" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's request for a writ of mandamus against Ohio Department of Rehabilitation and Correction officials (DRC), holding that Appellant failed to establish that he was entitled to a writ of mandamus.In his complaint Appellant sought to compel the removal of information from his legal file before his next parole-board hearing. The court of appeals denied the writ. The Supreme Court affirmed and denied as moot Appellant's motion to grant judgment in his favor, holding that Appellant's arguments on appeal were without merit. View "State ex rel. Robinson v. Chambers-Smith" on Justia Law

The Supreme Court denied Relator's complaint seeking a writ of mandamus ordering the Greene County Board of Elections to verify the signatures on his petition and to certify his name to the November 5, 2019 general election ballot as a candidate for Xenia Township Trustee, holding that Relator did not establish a clear legal right to the relief he sought or a clear legal duty on the part of the Board to provide it.The Board rejected Relator's petition and did not complete its verification of the signatures because the circulator statement on each part-petition indicated forty-four signatures - the total number on the entire petition - rather than the number of signatures on the individual part-petition. The Supreme Court denied the writ of mandamus sought by Relator, holding that, under the circumstances of this case, Relator did not have a clear legal right to have his name certified to the ballot. View "State ex rel. Combs v. Greene Cty. Bd. of Elections" on Justia Law

The Supreme Court denied the writ of prohibition sought by the village of Georgetown to prevent the Brown County Board of Elections from placing a tax-levy-reduction measure on the November 5, 2019 general election ballot, holding that the village was not entitled to relief on either of its propositions of law.In opposition to placement of the levy-reduction measure on the ballot the village (1) alleged that the board acted unreasonably and arbitrarily when it found the petition contained a sufficient number of valid signatures, and (2) challenged the substantive validity of the ballot measure. The Supreme Court denied the requested writ, holding (1) the petition had a sufficient number of valid signatures; and (2) the board did not abuse its discretion by approving the levy-reduction measure for the ballot. View "Village of Georgetown v. Brown County Board of Elections" on Justia Law

The Supreme Court denied the Cincinnati Enquirer's request for a writ of mandamus but granted an award of attorney fees and court costs, holding that the City of Cincinnati's redactions to body-camera footage were proper but that the Enquirer was entitled to reasonable attorney fees and court costs.The Enquirer requested public records, including body-camera footage taken by police officers' body cameras during the arrest of two men. The City denied the records request, and the Enquirer filed this original action for a writ of mandamus. The Supreme Court granted an alternative writ of mandamus and ordered the City to submit the body-camera videos to the court under seal. The City complied with the directive. Thereafter, the City provided the body-camera footage to the Enquirer but redacted the videos to obscure the faces of plainclothes officers who appeared in the footage. The Supreme Court concluded that the Enquirer was not entitled to a writ of mandamus because the City provided the requested videos and because the redactions were proper. However, the Court granted the Enquirer's request for reasonable attorney fees and costs. View "State ex rel. Cincinnati Enquirer v. Cincinnati" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's request for a writ of mandamus to compel the Toledo Correctional Institution (TCI) to produce "all interoffice communications and emails" related to Appellant's efforts to obtain size-12EEE boots, holding that the court of appeals correctly rejected Appellant's mandamus claim.In denying relief, the court of appeals determined that Appellant failed to plead facts with sufficient specificity to determine whether the issuance of a writ of mandamus was warranted. The Supreme Court affirmed, holding that Appellant failed to show that TCI possessed any records responsive to Appellant's request, and therefore, Appellant did not establish a legal right to the production of any records or show that TCI had a legal duty to produce any records. View "State ex rel. Alford v. Toledo Correctional Institution" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's order permanently enjoining enforcement of Ohio Rev. Code 9.75, which prohibits a public authority from requiring that contractors on public-improvement projects employ a specific number or percentage of the public authority's residents, holding that section 9.75 is a general law and prevails over local laws.The appellate court affirmed the trial court's order permanently enjoining enforcement of section 9.75, holding that Ohio Const. art. II, 34 did not authorize the General Assembly to infringe on the City of Cleveland's municipal home-rule authority under Ohio Const. art. XVIII, 3 to impose city-residency preferences in Cleveland's public-improvement contracts. The Supreme Court reversed and remanded the matter to the trial court to dissolve the injunction, holding that the statute provides for the comfort and general welfare of all Ohio construction employees and therefore supersedes conflicting local ordinances. View "Cleveland v. State" on Justia Law

In these consolidated appeals the Supreme Court affirmed the judgments of the court of appeals dismissing Appellant's petition for a writ of mandamus and second petition for a writ of mandamus, holding that even if the dismissals were based on an erroneous rationale, the dismissals were proper.Defendant was found guilty of several offenses. The court of appeals affirmed the convictions and sentence. Defendant later filed a petition for a writ of mandamus claiming that the trial judge had a legal duty to charge him by way of criminal complaint and that the common pleas court lacked subject matter jurisdiction because a criminal complaint was not filed. In his second mandamus petition Appellant sought an order to compel the trial judge to hold a new sentencing hearing and issue a new order dismissal all but one of his convictions. The court of appeals dismissed both petitions, concluding that Appellant's claims were barred by res judicata. The Supreme Court affirmed, holding that even if the court of appeals erred in granting the motions to dismiss based on res judicata the dismissals were proper because Appellant had an adequate remedy in the ordinary course of law. View "State ex rel. Sands v. Culotta" on Justia Law