Justia Ohio Supreme Court Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's petition for a writ of habeas corpus, holding that Appellant did not show that he was entitled to the writ.In his habeas corpus petition, Appellant, an inmate, argued that the Bureau of Sentence Computation miscalculated his prison term and that his jail-time credit was improperly calculated. The court of appeals dismissed the petition. The Supreme Court affirmed, holding (1) Appellant's prison term was properly calculated; and (2) Appellant's claim that he was entitled to additional jail-time credit was not cognizable in habeas corpus actions. View "State ex rel. Shafer v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the trial court's denial of Appellee's motion to withdraw a guilty plea based on his claim of ineffective assistance of counsel, holding that the trial court erred in denying Appellee's motion without considering the two-prong test for ineffective assistance of counsel established in Strickland v. Washington, 466 U.S. 668 (1984) and applied in the immigration context but that the court of appeals' remand order for a full evidentiary hearing was premature.In his motion, Appellee claimed ineffective assistance of counsel because his attorney had failed to advise him of the immigration consequences of his pleas. The trial court denied the motion. The court of appeals reversed and remanded to the trial court to conduct a hearing, concluding that the trial court erred by denying the motion without deciding whether counsel properly advised Appellee. The Supreme Court affirmed and remanded the matter to the trial court for application of the proper standard, holding that the trial court erred in denying Appellee's motion without considering the two-prong test for ineffective assistance of counsel established in Strickland and applied in Padilla v. Kentucky, 559 U.S. 356 (2010). View "State v. Romero" on Justia Law

The Supreme Court denied as moot Relator's complaint seeking a writ of mandamus against Larry Greene, the administrative assistant for the warden of the Southern Ohio Correctional Facility, to compel the production of public records, holding that Relator was not entitled to mandamus because he received the documents that he requested.After Relator, an inmate, submitted a public-records request he filed a complaint for writ of mandamus against Greene. Eight days later, Relator was provided with copies of the requested records. Greene filed a motion to dismiss on the grounds that Relator filed to attach certain documents to the complaint. Three months late, Relator filed a motion asking the Court to consider the affidavit and exhibits attached to his complaint as substantive evidence. The Supreme Court (1) denied the writ of mandamus as moot; (2) denied Relator's demand for statutory damages and court costs on the merits; and (3) denied Relator's motion to have the attachments to his complaint accepted as service as moot. View "State ex rel. Martin v. Greene" on Justia Law

The Supreme Court denied Appellee's motion to dismiss Appellant's appeal from the decision of the Board of Tax Appeals (BTA) that denied Appellant's claim for property-tax exemption for several parcels of land it owned, holding that Appellant timely perfected its appeal.As support for its motion to dismiss, Appellee argued that because Appellant did not initiate service by certified mail within the thirty-day period prescribed by Ohio Rev. Code 5717.04 for filing its notice of appeal, the Supreme Court must dismiss the appeal for lack of jurisdiction. The Supreme Court rejected Appellee's argument, holding that section 5717.04 does not state a timeline for the certified-mail service of the notice of appeal on the appellees, and it is not disputed that the notice of appeal was properly served on Appellee by certified mail. View "The City of Upper Arlington v. McClain" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition against an unnamed judge of the Summit County Court of Common Pleas, holding that Appellant's complaint failed to state a claim and was correctly dismissed.Appellant was found guilty of aggravated murder. Because he was charged under Ohio Rev. Code 2903.01(B), which requires that the death occurred during the commission of an underlying felony, and he was acquitted of the alleged underlying felony, Appellant alleged in his complaint that the law required him to be acquitted of aggravated murder. The court of appeals dismissed Appellant's complaint for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding (1) Appellant's mandamus complaint failed to state a claim and was correctly dismissed; and (2) Appellant failed to state a claim for relief in prohibition. View "State ex rel. Zander v. Judge of Summit County Common Pleas Court" on Justia Law

In this original action brought by Cuyahoga County Prosecuting Attorney Michael C. O'Malley seeking a writ of prohibition to prevent Cuyahoga County Court of Common Pleas Judge Michael J. Russo from exercising jurisdiction over a wrongful imprisonment claim filed by Joe D'Ambrosio and a writ of procedendo to compel Judge Russo to terminate D'Ambrosio's litigation, the Supreme Court granted Judge Russo's motion for judgment on the pleadings, holding that O'Malley was not entitled to either writ.D'Ambrosio commenced a wrongful imprisonment action in the common pleas court under Ohio Rev. Code 2743.48. The trial court granted summary judgment for D'Ambrosio. The Supreme Court reversed. Thereafter, D'Ambrosio filed a new complaint in common pleas court again asserting a wrongful imprisonment claim. The State moved for judgment on the pleadings, arguing that the mandate rule and the doctrines of law of the case and res judicata barred the action. The trial court denied the State's motion. The Supreme Court granted Judge Russo's motion for judgment on the pleadings, holding that O'Malley had not alleged facts supporting the issuance of a writ of prohibition or a writ of procedendo. View "State ex rel. O'Malley v. Russo" on Justia Law

The Supreme Court granted a peremptory writ prohibiting Judge Thomas O'Diam of the probate division of the Greene County Court of Common Pleas from enforcing his orders concerning the control of Courtroom 3 in the Greene County Courthouse and prohibiting Judge O'Diam from entering additional orders relating to the dispute over the control of Courtroom 3, holding that Judge O'Diam acted beyond his authority in issuing his orders requiring the Greene County Board of Commissioners to designate Courtroom 3 as the probate-division's courtroom.During this dispute, Courtroom 3 was under the control of the General Division of the Greene County Court of Common Pleas. Judge O'Diam ordered the Board to designate Courtroom 3 as the probate division's courtroom and to provide the probate division exclusive use of the room three days a week. The Board and Greene County sought a writ prohibiting the judge from enforcing his orders. In a related case, Judge O'Diam sought a writ of mandamus to enforce his orders. The Supreme Court granted a peremptory writ of prohibition with the qualification that its issuance was without prejudice to Judge O'Diam's claim that he was entitled to have the County pay his attorney fees and litigation expenses related to defending and attempting to enforce his orders. View "State ex rel. Greene County Board of Commissioners v. O'Diam" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that the arguments raised in the petition were not cognizable in habeas corpus.Appellant, an inmate, filed a habeas corpus petition arguing that his sentences were void for several reasons and that the indictment in his first case was invalid. The court of appeals dismissed the petition, concluding that Appellant had an adequate remedy at law to raise most of his claims and that another claim was without merit. The Supreme Court affirmed, holding that Appellant's claims were not cognizable in habeas corpus. View "Smith v. Sheldon" 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 the chief of the Ohio Bureau of Sentencing Computation (BSC) to recompute his sentences, holding that although the court of appeals' reasoning was incorrect, its result was correct.Appellant, an inmate, filed a declaratory judgment action against BSC arguing that it had not properly computed state court sentences imposed in 1966 and 1986 and seeking a judgment declaring his proper sentence, parole-eligibility date, and sentence-expiration date. The court of common pleas granted summary judgment for BSC. The court of appeals affirmed. Appellant then filed a writ of mandamus again arguing that the trial court improperly imposed consecutive sentences instead of concurrent sentences. The court of appeals granted the BSC's motion to dismiss for failure to state a claim. The Supreme Court affirmed, holding that because Appellant had an adequate remedy at law to raise his claims, he could not now raise them in a mandamus action. View "State ex rel. Miller v. Bower" 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 a handgun and other evidence obtained during a Terry stop, holding that the stop did not violate the Fourth Amendment to the United States Constitution.After hearing the sound of gunshots, two police officers drove to the area where the shots seemed to be coming from. With their guns drawn, the officers detained Defendant, the only person in the area. The officers patted Defendant down and retrieved a handgun from his jacket. Defendant was charged with carrying a concealed weapon. Defendant filed a motion to suppress, arguing that the officers lacked reasonable suspicion to detain him. The trial court denied the motion to suppress. The court of appeals reversed, concluding that the officers had reasonable suspicion to perform an investigative stop. The Supreme Court reversed, holding that, based on the totality of the circumstances, the police officers had reasonable suspicion to stop Defendant and did not convert the stop into an arrest by approaching Defendant with their weapons drawn. View "State v. Hairston" on Justia Law