Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of prohibition to vacate his criminal convictions, holding that the court of appeals correctly concluded that Appellant's claims were 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 prohibition against the now-retired judge who presided over his criminal case and the judge who replaced the previous judge, claiming that his judgment of conviction should be vacated because certain evidence was improperly admitted at trial, venue was not properly established, his convictions were not supported by sufficient evidence, and the prosecutor committed misconduct. The court of appeals dismissed the petition sua sponte. The Supreme Court affirmed, holding that the petition was properly dismissed because (1) the common pleas court had subject matter jurisdiction to hear Appellant's criminal case; (2) Appellant's appeal of his criminal convictions constituted an adequate remedy at law; and (3) Appellant's claims were barred by res judicata. View "State ex rel. Kerr v. Pollex" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against the Ohio Department of Rehabilitation and Correction (DRC), holding that the court of appeals correctly dismissed Appellant's complaint for his failure to submit the statement of inmate account required by Ohio Rev. Code 2969.25(C)(1).Appellant, an inmate, filed a petition seeking a writ of mandamus ordering the DRC to aggregate his prison terms "in a manner consistent with the law." The court of appeals dismissed the petition sua sponte because Appellant had failed to comply with section 2969.25(C)(1). On appeal, Appellant argued that he filed with his petition an inmate account statement that substantially with section 2969.25(C). The Supreme Court affirmed, holding that because section 2969.25(C) does not permit substantial compliance the court of appeals correctly dismissed Appellant's complaint. View "State ex rel. Roden v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the decision of the Board of Tax Appeals (BTA) affirming a tax assessment against Rockies Express Pipeline, LLC (Rockies), holding that Rockies' gross receipts for tax year 2015 from the transportation of natural gas within the state of Ohio were not excluded from taxation under Ohio Rev. Code 5727.33(B)(1) as "receipts derived wholly from interstate business" and that such taxation does not violate the Commerce Clause.Rockies is an interstate pipeline that transports natural gas for others. For tax year 2015, the Ohio Tax Commissioner assessed Rockies on transactions in which natural gas entered and exited Rockies' pipeline within Ohio. Rockies petitioned the tax commissioner for reassessment, arguing that its receipts derived wholly from interstate business and were thus eligible for exclusion under section 5727.33(B)(1). The tax commissioner upheld the assessment. The BTA affirmed. The Supreme Court affirmed, holding (1) Rockies did not meet its burden of showing that its receipts fall under the exclusion in section 5727.33(B)(1) as "receipts derived wholly from interstate business"; and (2) imposing the tax under these circumstances does not violate the Commerce Clause because Rockies has substantial nexus with Ohio based on its physical presence within the State. View "Rockies Express Pipeline, LLC v. McClain" on Justia Law

The Supreme Court dismissed this appeal from the court of appeals' dismissal of Appellant's petition for a writ of prohibition against Summit County Court of Common Pleas and Judge Mary Margaret Rowlands, holding that this cause was moot.National Collegiate Student Loan Trust 2007-2 filed a civil action against Appellant in the court of common pleas. Judge Rowlands demised the case without prejudice and then reinstated the case after considering National Collegiate's motion for relief from judgment. Petitioner filed a petition for a writ of prohibition alleging that Judge Rowland lacked jurisdiction to issue the order reinstating the case. The court of appeals dismissed the petition for failure to state a claim. Appellant appealed. Judge Rowlands claimed that the appeal was moot because, during the pendency of the appeal, she dismissed National Collegiate's case a second time. The Supreme Court dismissed the appeal, holding that the cause was moot and that no exception to the mootness doctrine applied. View "State ex rel. Ames v. Summit County Court of Common Pleas" on Justia Law

The Supreme Court affirmed the determination of the board of tax appeals (BTA) of the 2015 tax year value of an apartment complex located in Franklin County, holding that the BTA's decision was reasonable and lawful.At issue was whether the BTA erred in deciding that the sale price paid for the transfer of ownership of a corporate entity, Palmer House Borrower, LLC (Palmer) should be presumed to constitute the value of the real estate owned by that entity. Palmer further asserted that the BTA improperly admitted and relied upon the submitted evidence of the transfer and sale. The Supreme Court affirmed, holding (1) the BTA reasonably considered the sale and conveyance documentation; (2) the BTA reasonably determined that the transaction was, in substance, a sale of the real estate; (3) the appraisal offered by Palmer was not the only evidence of value; and (4) Palmer did not show that the BTA's decision violated Ohio Const. art. XII, 2. View "Columbus City Schools Board of Education v. Franklin County Board of Revision" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting summary judgment to Judge Joseph D. Russo and denying Sell Jefferson a writ of mandamus, holding that Jefferson's claims were barred by res judicata.In 1975, Jefferson was convicted of aggravated robbery and aggravated robbery and sentenced to life imprisonment. The Ohio Department of Rehabilitation and Correction was not notified of Jefferson's aggravated murder conviction and life sentence. As a result, the Adult Parole Authority granted Jefferson final release in 1982. In 1985, Jefferson was indicted for several felony counts. Jefferson was convicted and sentenced to a prison term, to be served concurrently with his 1975 sentence. Jefferson raised numerous challenges to his arrest and reincarceration in the 1975 case, without success. Jefferson then brought this proceeding, arguing that his due process rights were violated. The court of appeals concluded that the claims in Jefferson's complaint were barred by res judicata. The Supreme Court affirmed, holding that summary judgment was properly granted. View "State ex rel. Jefferson v. Russo" on Justia Law

The Supreme Court granted Relator's request for a writ of mandamus to compel Karla Hack, the former Marion County Court Reporter, to inform him of the fee for a copy of the transcript of his 2009 sentencing hearing, holding that Relator established all three requirements necessary to obtain a writ of mandamus.Relator, an inmate in the custody of the Ohio Department of Rehabilitation and Correction, filed a motion to compel the court reporter to produce a copy of the sentencing transcript and inform Relator of the fee for a copy of it. Relator then filed a motion to add the county court reporter's office and the current county court reporter as respondents, stating that Hack had retired and that he was unable to determine who the current court reporter was. The Supreme Court granted the motion and the writ, holding that Relator established that he was entitled to the writ. View "State ex rel. Newsome v. Hack" on Justia Law

In this dispute over which court has jurisdiction over an employer's claim against the Ohio Bureau of Workers' Compensation (BWC) for the reimbursement of alleged excessive premiums paid by the employer the Supreme Court held that the claim was a legal claim, not an equitable one, and therefore, the court of claims had exclusive jurisdiction over the case.The City of Cleveland filed a complaint in the Cuyahoga County Court of Common Pleas alleging that the BWC charged the City inflated premiums for workers' compensation insurance in order to make up for discounts the BWC provided other employers. The BWC filed a motion to dismiss, arguing that the common pleas court lacked subject matter jurisdiction over the lawsuit and that the court of claims had exclusive jurisdiction. The trial court denied the motion and granted partial summary judgment to the City. The court of appeals affirmed. The Supreme Court reversed, holding that the City's claim sounded in law and must proceed through the court of claims, which has exclusive jurisdiction over legal claims against the BWC. View "City of Cleveland v. Ohio Bureau of Workers' Compensation" on Justia Law

The Supreme Court affirmed the decision of the board of tax appeals (BTA), holding that Cleveland's taxation of Appellant's employment compensation in 2014 and 2015 was required under municipal law and did not violate Appellant's due process rights, despite the fact that Appellant did not work or live in the city of Cleveland during the tax years at issue.Appellant was employed by the Sherwin-Williams Company from 1980 until she retired in 2009 and moved to Florida. Sherwin-Williams compensated Appellant, in part, with stock options during her employment. Appellant exercised some of those options in 2014 and 2015, and Cleveland collected income tax on their value. Appellant sought refunds from the city based on the fact that she resided in Florida during the tax years at issue. Cleveland Board of Income Tax Review denied the refunds, and the BTA affirmed. The Supreme Court affirmed, holding that Appellant's arguments challenging the taxation failed. View "Willacy v. Cleveland Board of Income Tax Review" on Justia Law

In this certified-conflict case, the Supreme Court held that when an indigent defendant makes an ineffective assistance of counsel claim based upon counsel's failure to request a waiver of court costs, a reviewing court must apply the test in State v. Bradley, 538 N.E.2d 373 (Ohio 1989) for determining whether a defendant received ineffective assistance of counsel.Defendant was convicted of assaulting a peace officer. The trial court assessed court costs against Defendant, despite his indigent status. On appeal, the court of appeals determined that Defendant was not prejudiced by trial counsel's failure to request a waiver of costs and that the basis for a finding of ineffective assistance of counsel for failure to request such a waiver no longer exists. The Supreme Court reversed, holding (1) when trial counsel fails to request that the trial court waive court costs on behalf of an indigent defendant, a determination of prejudice for purposes of an ineffective assistance of counsel analysis deeds on whether there is a reasonable probability that the trial court would have granted the request to waive costs had one been made; and (2) the court of appeals incorrectly analyzed the prejudice prong of the ineffective-assistance of counsel analysis set forth in Bradley. View "State v. Davis" on Justia Law