Justia Ohio Supreme Court Opinion Summaries

The Supreme Court denied a writ of prohibition sought by the Ohio High School Athletic Association (OHSAA) to prohibit Judge Robert Ruehlman from taking further action in a lawsuit filed against it in the Hamilton County Court of Common Pleas, holding that Judge Ruehlman did not patently and unambiguously lack jurisdiction.After the OHSAA adopted new rules governing postseason competitions Judge Ruehlman granted a temporary restraining order enjoining the application of the rules in cases where the high school enrolled a student who attended seventh and eighth grades at one of its traditional Catholic Feeder Schools. The OHSAA then filed this action to prevent Judge Ruehlman from taking further action in the case and to order him to vacate the temporary restraining order. The Supreme Court denied the writ, holding that the subject matter of this dispute fell within the jurisdiction granted by the Ohio Constitution and Revised Code to the Hamilton County Court of Common Pleas and that Judge Ruehlman properly exercised the subject-matter jurisdiction of the Hamilton County Court of Common Pleas. View "Ohio High School Athletic Ass'n v. Ruehlman" on Justia Law

The Supreme Court granted a writ of mandamus ordering the Franklin County Board of Elections to reinstate Robert Bender's certification to the November 2019 ballot as the Libertarian Party candidate for Reynoldsburg City Council, Ward 3, holding that the Board abused its discretion by removing Bender from the ballot.Although the Board initially certified Bender to the ballot, it sustained a protest challenging the validity of some of the signatures on Bender's petition. The Supreme Court granted a writ of mandamus ordering the Board to reinstate Bender as a candidate for the November 2019 general election, holding that no evidence established that the protestor had standing to bring the protest and that the time for sua sponte action by the Board had passed. View "State ex rel. Bender v. Franklin County Board of Elections" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's order confirming the sale of Homeowners' property after the trial court entered a foreclosure decree in favor of Bank, holding that the foreclosure decree was a final, appealable order.Homeowners challenged the trial court's entry of a foreclosure decree in favor Bank. The court of appeals dismissed the appeal for lack of a final, appealable order because the foreclosure decree did not state the amounts owed to two other lienholders. During the appeal, Homeowners' property was sold at a sheriff's sale. Homeowners' second appeal challenged the trial court's order confirming the sale of the property. The court of appeals concluded that the law-of-the-case doctrine required adherence to its earlier decision that the foreclosure decree was not a final, appealable order, and therefore, the trial court had no authority to confirm the sale. The Supreme Court reversed and reinstated the trial court's confirmation of sale, holding that the foreclosure decree against Homeowners was a final, appealable order that fully addressed the rights and responsibilities of all parties. View "Farmers State Bank v. Sponaugle" on Justia Law

The Supreme Court granted a writ of prohibition and denied a requested writ of mandamus in this original action by WBNS 10-TV, Inc. against Franklin County Common Pleas Domestic Relations Court Judge Monica Hawkins, holding that prohibition was the proper vehicle to challenge the order denying courtroom access to 10-TV that was issued by Judge Hawkins without an evidentiary hearing and that this decision rendered moot 10-TV's alternative request for a writ of mandamus.After Judge Hawkins was arrested for driving under the influence a reporter for 10-TV made a written request for media access to the proceedings in Judge Hawkins's courtroom scheduled for that same day. Judge Hawkins denied the request without conducting the required closure hearing. 10-TV then commenced an original action seeking writs of prohibition and mandamus. In response, Judge Hawkins agreed that a writ of prohibition should issue. The Supreme Court granted the writ of prohibition, denied the request for a writ of mandamus as moot, and denied the requests in 10-TV's emergency motion for peremptory writs of prohibition and mandamus as moot. View "State ex rel. WBNS 10-TV, Inc. v. Hawkins" on Justia Law

In this tort action against Cuyahoga County the Supreme Court affirmed the judgments of the lower courts applying Ohio Rev. Code 2744.09(B) to reject the County's assertion of political subdivision immunity, holding that section 2744.09(B) does not require a plaintiff to have been employed by the political-subdivision employer at the time the plaintiff filed the lawsuit.Section 2744.09(B) provides that the Political Subdivision Tort Liability Act does not apply to civil actions by an employee "against his political subdivision relative to any matter that arises out of the employment relationship between the employee and the political subdivision." Plaintiff sued the County, her former employer, for false-light invasion of privacy based on a statement allegedly made regarding the termination of Plaintiff's employment. The trial court denied the County's motion for summary judgment. The court of appeals affirmed, holding that Plaintiff's claim arose out of her employment relationship with the County, and the County was not immune from liability pursuant to the express exception in section 2744.09(B). The Supreme Court affirmed, holding (1) the statute does not require an ongoing employment relationship between the plaintiff and the political-subdivision employer; and (2) Plaintiff's false-light claim was relative to a matter that arose out of the employment relationship in this case. View "Piazza v. Cuyahoga County" on Justia Law

In this case involving the correct interpretation of Ohio Rev. Code 3107.07(A), the statute that sets forth when the adoption of a minor child may proceed without a parent's consent, the Supreme Court held that a parent's nonsupport of his or her minor child pursuant to a judicial decree does not extinguish the requirement of that parent's consent to the adoption of the child.Appellant, the child's stepfather, filed a petition seeking to adopt B.I. and arguing that Father's consent was not required under section 3107.07(A) because Father had failed to provide support for B.I. during the year preceding the filing of the petition. During that year, Father was not subject to a child-support order pursuant to a zero-support order. The magistrate concluded that Father's consent to the adoption was not required. The probate court overruled the magistrate, concluding that a valid, zero-support order provides justifiable cause for a failure to provide maintenance and support under section 3107.07(A). The Supreme Court affirmed, holding that, pursuant to section 3107.07(A), a parent's nonsupport of his or her minor child pursuant to a zero-support order of a court of competent jurisdiction does not extinguish the requirement of that parent's consent to the adoption of the child. View "In re Adoption of B.I." on Justia Law

In this case involving the manner in which earnings from commissions figure into the calculation of child support, the Supreme Court held that Ohio Rev. Code 3119.05(D) covers income earned from commissions and that the juvenile court and court of appeals erred by failing to apply its mandatory terms.After a magistrate awarded child support to Mother, Father objected to the child-support determinations, asserting that the magistrate erred in including projected commissions when calculating his gross income. The juvenile court adopted the order of the magistrate. The court of appeals affirmed, concluding that commissions were not governed by section 3119.05(D), and therefore, the trial court did not err by including Father's projected commissions in its calculation of his gross annual income. The Supreme Court reversed, holding that commissions are included with the terms of section 3119.05(D) and must be calculated as provided in that section when determining a parent's annual gross income. View "A.S. v. J.W." on Justia Law

The Supreme Court dismissed this original action in mandamus for failure to state a claim, holding that Relator was not entitled to mandamus relief.Relator, an inmate, brought this action against Respondents, nine public officials in Scioto and Franklin Counties, seeking to compel Respondents to investigate and prosecute his allegations of criminal activity and to issue arrest warrants based on the allegations. Respondents filed motions to dismiss, arguing that the complaint failed to comply with Ohio Rev. Code 2969.25's filing requirements. The Supreme Court denied the motions to dismiss because section 2969.25 did not apply. Under an independent assessment of the sufficiency of the mandamus complaint, the Court nonetheless dismissed the complaint, holding that the complaint failed to state a claim for relief in mandamus because Relator failed to allege facts that, if proved, would establish a clear legal duty to act on the part of Respondents. View "State ex rel. Evans v. Tieman" on Justia Law

The Supreme Court affirmed the orders of the Ohio Power Siting Board approving the application of 6011 Greenwich Windpark, LLC to add three new wind-turbine models to the list of turbines suitable for Greenwich Windpark's proposed wind farm in Huron County, holding that the Board's approval of Greenwich Windpark's application did not require an amendment of its certificate.On appeal, Appellant argued that, in approving the proposed changes, the Board acted unlawfully and unreasonably by refusing to subject Greenwich Windpark's application to the enhanced minimum turbine-setback requirements applicable to any certificate "amendment" under the current versions of Ohio Rev. Code 4906.20 and 4906.201. The Supreme Court affirmed, holding that the Board adopted a reasonable and practical approach for determining when an amendment is necessary for purposes of the statutes and that, under the circumstances, the Board's decision was not unlawful or unreasonable. View "In re Application of 6011 Greenwich Windpark, LLC" on Justia Law

The Supreme Court affirmed in part and reversed in part the order of the Public Utilities Commission of Ohio (PUCO) that modified and approved an electric-security plan (ESP) for the FirstEnergy Companies, holding that the Commission erred in modifying the ESP to add a distribution modernization rider (DMR) that was not part of the original application.The Commission concluded that the DMR, which allowed the FirstEnergy Companies to collect between $168 to $204 million in extra revenue per year, was valid under Ohio Rev. Code 4928.143(B)(2)(h) because the revenue it generated would purportedly serve as an incentive for the companies to modernize their distribution systems. The Supreme Court reversed the Commission's order as it related to the DMR and remanded with instructions to remove the DMR for the companies' ESP, holding that the DMR did not qualify as a proper incentive under section 4928.143(B)(2)(h) and that the conditions placed on the recovery of DMR revenue were not sufficient to protect ratepayers. View "In re Application of Ohio Edison Co." on Justia Law