Justia Ohio Supreme Court Opinion Summaries

The Supreme Court granted C.V.'s request for a writ of prohibition against the Greene County Juvenile Court judge, holding that C.V. was entitled to a writ of prohibition against the Greene County Juvenile Court judge on the ground that he patently and unambiguously lacked jurisdiction to approve C.V.'s agreement to permanently surrender her child to the custody of Adoption Link, Inc.C.V. did not know she was pregnant when she gave birth to N.V. Four days later, C.V. executed a permanent surrender of child agreement, assigning permanent custody of N.V. to Adoption Link. The juvenile court judge approved the surrender agreement, granted Adoption Link permanent custody, and terminated C.V.'s parental rights. The Supreme Court held (1) the juvenile court judge's purported approval of the surrender agreement between C.V. and Adoption Link was a legal nullity and must be voided; (2) C.V.'s request for a writ of prohibition against the Greene County Probate Court judge to prevent him from exercising power over N.V.'s adoption proceedings is denied; and (3) C.V.'s request for a writ of habeas corpus is denied because C.V. has an adequate remedy available to her in the ordinary course of law. View "State ex rel. C.V. v. Adoption Link, Inc." 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 correctly concluded that Appellant's petition failed to comply with the requirements of Ohio Rev. Code 2725.04(D).Appellant was imprisoned for various offenses. Appellant filed a petition for a writ of habeas corpus against the warden of the Marion Correctional Institution claiming that his maximum aggregate sentence had expired. The court of appeals granted the warden's motion to dismiss or for summary judgment, holding that Appellant had failed to attach relevant commitment papers and that his claims were barred by res judicata. View "Dailey v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's petition for a writ of prohibition to bar East Cleveland Municipal Court Judge William Dawson from continuing to preside over Euclid Lake Properties, LLC. v. Tri Eagle Fuels, LLC, East Cleveland M.C. case No. 17CVG01000, holding that jurisdiction was not patently and unambiguously lacking in the municipal court.Lessee signed a commercial lease to rent certain property from Lessor for fifteen years. After Lessor alleged that Lessee was in default of the lease and served Lessee with a notice to vacate the premises Lessee filed suit alleging that Lessor, in fact, had breached the lease. Before Lessor filed an answer it filed a forcible-entry-and-detainer (FE&D) action against Lessee. The case was assigned to Judge Dawson. Lessee filed an original action for a writ of prohibition alleging that Judge Dawson lacked jurisdiction to proceed in the municipal court case based on the jurisdictional priority rule. The court of appeals denied the writ of prohibition. The Supreme Court affirmed, holding that Judge Dawson was not deprived of jurisdiction over the FE&D action. View "State ex rel. Tri Eagle Fuels, LLC v. Dawson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals vacating Defendant's convictions for violation of Defendant's right to a speedy trial, holding that speedy-trial time is tolled when a defendant's request for a continuance is made in open court and on the record or the reasons for the request are evidence from the record.The trial court denied Defendant's motion to dismiss the misdemeanor charges against her for violation of her right to a speedy trial, concluding that, after factoring in the periods of delay attributable to Defendant, ninety days had not elapsed from the date of her arrest to the date she filed her motion to dismiss. The court of appeals reversed and vacated Defendant's convictions, holding that the continuances in this case, while entered on behalf of Defendant, must be charged against the State because the trial court's journal entries either failed to identify Defendant as the requesting party or failed to explain the precise reasons for the delay. The Supreme Court reversed, holding that speedy-trial time is not chargeable to the State when the reasons for the defendant's request for a continuance are evident from the record, regardless of whether or not the trial court specifically journalizes those reasons on its docket sheet. View "State v. Martin" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Appellant's Civ.R. 60(B) motion for relief from judgment and denied the five motions that Appellant filed in this case, holding that the court of appeals did not abuse its discretion in denying Appellant's motion.Appellant filed a complaint for a writ of mandamus arguing that he was entitled to be released from prison. The court of appeals dismissed the complaint, concluding that Appellant was not entitled to a writ of mandamus. Appellant then filed a Civ.R. 60(B) motion seeking relief from the court of appeals' judgment. The court of appeals denied the motion. Appellant later moved for relief from judgment on the same grounds previously asserted. The court of appeals denied the motion on res judicata grounds. The Supreme Court affirmed after denying the Ohio Department of Rehabilitation and Correction's motion to dismiss, holding (1) the court of appeals correctly denied Appellant's second Civ.R. 60(B) motion on the basis of res judicata; and (2) none of Appellant's pending motions had merit. View "State ex rel. Richard v. Chambers-Smith" on Justia Law

In this quo warranto case in which the attorney general sought to dissolve Omar Ibn El Khattab Mosque, Inc. the Supreme Court granted Appellants' motion for reconsideration of the Court's decision affirming the decision of the court of appeals granting the writ, vacated its earlier decision, reversed the judgment of the court of appeals, and remanded the case with instructions to deny the writ, holding that this Court's initial decision was in error.The Ohio attorney general filed a complaint for a writ of quo warranto seeking to dissolve the corporation and appoint a receiver, alleging that the corporation violated three rules of corporate governance. The court of appeals issued a writ of quo warranto. The Supreme Court affirmed. The Court subsequently granted Appellants' motion for reconsideration and held that the writ should not issue. View "State ex rel. Yost v. Omar Ibn El Khattab Mosque, Inc." on Justia Law

The Supreme Court affirmed the court of appeals' judgment denying Carol Fradette's petition for a writ of prohibition against Joseph Fradette and Judge Rosemary Grdina Gold and Magistrate Michelle Edwards of the Cuyahoga County Court of Common Pleas, Domestic Relations Division, holding that the court of appeals correctly denied the writ.In 1999, Carol and Joseph were divorced, and Carol was awarded spousal support. In 2017, Joseph filed a fourth motion to terminate or modify spousal support, which was scheduled for a hearing before Magistrate Edwards. Carol moved a motion to dismiss, which Judge Gold denied. In 2018, Carol filed this writ of prohibition arguing that Judge Gold exceeded her statutory authority by permitting Joseph to file multiple motions to terminate or modify spousal support. The court of appeals denied the writ. The Supreme Court affirmed, holding that Carol was not entitled to the writ. View "Fradette v. Gold" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus and/or procedendo to compel Franklin County Court of Common Pleas Judge William H. Woods to issue a corrected sentencing entry, holding that Appellant had an adequate remedy in the ordinary course of the law by way of appeal.In 2006, the common pleas court issued an entry resentencing Defendant for his 2005 convictions for murder and felonious assault. In 2017, Defendant filed in the court of appeals a complaint for a writ of mandamus and/or procedendo arguing that he was entitled to a new sentencing entry that complied with Ohio Rev. Code 2505.02 and Crim.R. 32(C). The court of appeals dismissed the complaint for failure to state a claim. The Supreme Court affirmed, holding that Appellant's action was barred because he had an adequate remedy at law. View "State ex rel. White v. Woods" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus to compel Appellee, Judge Megan E. Shanahan of the Hamilton County Court of Common Pleas, to provide public records relating to his incarceration, holding that Appellant improperly sought records under the Public Records Act rather than the Rules of Superintendence.Appellant was convicted of aggravated burglary, abduction, and rape. Appellant later filed motions seeking the inspection and release of public records relating to his case. Judge Shanahan denied the motions, noting that Appellant could access all publicly available records through the clerk of courts. Appellant then filed his petition for a writ of mandamus. The court of appeals dismissed the writ, concluding that since Appellant was incarcerated, a sentencing court must first determine that the court records were necessary to support a justiciable claim. The Supreme Court affirmed but on different grounds, holding that the court of appeals erred in applying the Ohio Public Records Act, Ohio Rev. Code 149.43, to Appellant's records request and that the court of appeals correctly dismissed the case. View "State ex rel. Husband v. Shanahan" 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 Warden Brandeshawn Harris, holding that Appellant's underlying claims were not cognizable in habeas corpus.Appellant filed in the court of appeals a petition for a writ of habeas corpus arguing that that, as a result of several errors, he had already served his total sentence. The court of appeals granted the warden's motion to dismiss for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding that Appellant's claims were not cognizable in habeas corpus. View "Rock v. Harris" on Justia Law