Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals dismissing the State's appeal from the order of the trial court granting Defendant's motion for a new trial based on insufficient evidence, holding that the court of appeals was not correct in dismissing the State's appeal.The court of appeals premised its dismissal of the State's appeal on principles of double jeopardy and on its application of Ohio Rev. Code 2945.67. The Supreme Court reversed, holding (1) the double jeopardy protection does not prevent the State from appealing the trial court's order granting the motion for a new trial but, rather, only prevents the State from retrying the defendant in the event the State is unsuccessful on appeal; and (2) section 2945.67, which delineates when the State may appeal in a criminal case, does not require dismissal of the State's appeal. View "State v. Ramirez" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court denying Defendant's motion to suppress, holding that a court may consider evidence beyond the four corners of a search warrant affidavit in determining whether an officer reasonably and in good faith relied on that warrant.Defendant was indicted for sexual imposition and voyeurism. Defendant filed a motion to suppress seeking to invalidate a search warrant authorizing the search of his home on the basis that the warrant affidavit contained materially false statements. The trial court ultimately denied the motion to suppress. At issue on remand was whether a detective's testimony regarding his unrecorded conversation with the judge at the time of the approval of the warrant was admissible at the suppression hearing. The court of appeals reversed, holding that the testimony was inadmissible and that the good-faith exception did not apply. The Supreme Court reversed, holding (1) in deciding whether the good-faith exception to the exclusionary rule applies to a search conducted under a search warrant, a court can consider sworn but unrecorded oral information that the police gave to the judge; and (2) because application of the exclusionary rule would not serve to deter any bad police conduct, suppression was unwarranted. View "State v. Dibble" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that reasonable parental discipline is not a component of the physical-harm element on Ohio's domestic violence and assault statues but, rather, is an affirmative defense to a charge under those statutes, holding that reasonable parental discipline is an affirmative defense.Defendant was charged with one third-degree felony count of domestic violence and one first-degree misdemeanor count of assault for allegedly beating the seven-year-old son of his live-in girlfriend for acting out at school. During trial, Defendant argued that his conduct was a reasonable exercise of parental discipline and corporal punishment. The trial court found Defendant guilty of the charges. The court of appeals affirmed, holding that treating reasonable parental discipline as an affirmative defense and placing the burden of proving that defense upon the accused does not violate due process. The Supreme Court affirmed, holding (1) proof of unreasonable parental discipline is not a component of the physical harm element of the offenses; (2) reasonable parental disciplines an affirmative defense; and (3) treating reasonable parental discipline as an affirmative defense does not unconstitutionally place the burden of proof on the defendant. View "State v. Faggs" on Justia Law

The Supreme Court denied a writ of mandamus sought by Tiffany White and Tiffany White 4 for the People compelling the Franklin County Board of Elections to place White's name on the March 17, 2020 primary ballot as a candidate for the Democratic Party nomination for the office of state representative for the 25th Ohio House District, holding that White did not establish that she had a clear legal right to have her name appear on the ballot.The Board informed White that her name would not appear on the ballot because her petition was one signature short of the required fifty signatures. Before the Supreme Court, White asserted that the Board abused its discretion by failing to validate three signatures on her nominating petition. White also filed a motion to strike the brief of amicus curiae Miranda Lange. The Supreme Court denied the writ and motion to strike, holding (1) White failed to establish by clear and convincing evidence that the three disputed petition signatures were genuine or that the Board abused its discretion in rejecting them; and (2) White was not entitled to a motion to strike. View "State ex rel. White v. Franklin County Board of Elections" 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 the court of appeals properly dismissed the habeas corpus petition.In dismissing the petition, the court of appeals concluded that Appellant had failed to attach all his commitment papers to the petition and failed to state a proper claim for relief in habeas corpus. Further, the court found that the petition was barred under the doctrine of res judicata. The Supreme Court affirmed, holding that Appellant's failure to attach commitment papers related to his convictions was a fatal defect and that Appellant's petition failed to state a claim cognizable in habeas corpus. View "State ex rel. Kerr v. Turner" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against the warden of the Lake Erie Correctional Institution, holding that the court of appeals correctly dismissed Appellant's habeas petition for failure to comply with Ohio Rev. Code 2969.25(A).Appellant filed a petition for a writ of habeas corpus alleging that he was entitled to immediate release from prison because his sentences had expired. The court of appeals dismissed the complaint for failure to comply with section 2969.25(A). Appellant appealed. After briefing was completed, Appellant filed a motion for certified copies of the record. The Supreme Court denied the motion and affirmed the court of appeals' dismissal of the habeas petition, holding that dismissal was proper because Appellant did not comply with section 2969.25(A). View "Robinson v. Fender" on Justia Law

The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's appeal of his conviction for two counts in an indictment because of a "hanging charge," holding that, in this case, the trial court's finding that Appellant was incompetent to stand trial on the pending charge operated as a de facto severance of that count from the counts of conviction.A jury found Appellant guilty on two counts in an indictment and hung on a third count. Appellant was sentenced to imprisonment on the two counts on which he was convicted, but the third count remained pending. Because of the "hanging charge," the court of appeals dismissed Appellant's appeal from his convictions for lack of a final, appealable order. The Supreme Court reversed, holding that when a defendant is convicted and sentenced on fewer than all counts of a multicount indictment and the State is prevented from retrying the defendant on the remaining counts due to a finding that the defendant is incompetent to stand trial, the incompetency finding effectively severs the charges, and the defendant may appeal his or her conviction and sentence. View "State v. Craig" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of prohibition and dismissed as moot the motions Appellant filed in connection with the complaint, holding that the court of appeals correctly dismissed the complaint.In his complaint, Appellant sought to vacate charging orders and receivership orders concerning his membership interests in two limited liability companies, asserting that the orders exceeded the authority of Henry County Court of Common Pleas Judge John Collier. The court of appeals dismissed the complaint, concluding that Judge Collier did not patently and unambiguously lack jurisdiction to enter a charging order or to appoint a receiver. The Supreme Court affirmed, holding that because Judge Collier had subject matter jurisdiction to enter a charging order and to appoint a receiver, Appellant did not show that the judge patently and unambiguously lacked jurisdiction. View "State ex rel. Kerr v. Collier" 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 the petition did not comply with the mandatory filing requirements of Ohio Rev. Code 2725.04 and that Appellant's claims were not cognizable in habeas corpus.Appellant was arrested and held in jail on a felony charge. The municipal court scheduled a preliminary hearing but then granted the State's motion for a continuance. Appellant later filed a petition for a writ of habeas corpus against the county sheriff arguing that he was entitled to immediate release because the municipal court had failed to conduct a preliminary hearing within ten days after his arrest and that the continuance was fatally flawed. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant's petition was fatally defective and that Appellant's claims were not cognizable in habeas corpus. View "Davis v. Sheldon" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court dismissing Plaintiff's wrongful-termination-in-violation-of-public-policy claim, holding that Plaintiff's dismissal did not jeopardize the public policy identified by the trial court and that Plaintiff did not satisfy the jeopardy element of her wrongful-termination-in-violation-of-public-policy claim.Plaintiff alleged that her employer wrongfully terminated her employment because she had challenged the employer for failing accurately to report her earnings to the Bureau of Unemployment Compensation. The trial court dismissed the complaint, concluding that dismissing employees under such circumstances would not jeopardize the stated public policy manifested in the provisions of Ohio Rev. Code Chapter 4141 and that section 4141.27 sets forth an adequate remedy for violating the public policy embodied in the statute. The court of appeals reversed, concluding that the trial court erred by determining that Plaintiff could not satisfy the jeopardy element and that the statutory remedies contained in Chapter 4141 was insufficient to protect Plaintiff's interests. The Supreme Court reversed, holding that the remedies in Chapter 4141 are sufficient to protect society's interest in the public policy that employers accurately report employees' pay and tips and the lack of a personal remedy for the dismissed employee does not jeopardize the stated public policy. View "House v. Iacovelli" on Justia Law