Justia Ohio Supreme Court Opinion Summaries

In this dispute over credit provisions in a real estate purchase agreement, the Supreme Court reversed the decision of the court of appeals reversing the trial court's grant of summary judgment in favor of Plaintiff, the buyer of a franchise business and the real property on which it sat, holding that the court of appeals erred.The parties in this case structured the agreement for the sale of the real property to include adjustments that would be made to the overall purchase price based on circumstances present at the time of the closing. At closing, the parties disagreed how one of the credit provisions - the Rents Credit - should be interpreted. The trial court granted summary judgment to Plaintiff as to its request for declaratory judgment interpreting the Rents Credit clause. The court of appeals ultimately reversed, concluding that the plain language of the Rents Credit clause led to a "manifestly absurd result." The Supreme Court reversed, holding (1) the language of the Rents Credit is plain and unambiguous and supports only the interpretation asserted by Plaintiff; and (2) there is no basis on which to conclude that the plain language of the Rents Credit results in a manifest absurdity. View "Beverage Holdings, LLC v. 5701 Lombardo, LLC" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of aggravated murder and sentence of death for one of the murders but vacated the sentence, holding that the trial court erred in ruling that Defendant was not intellectually disabled.On appeal, Defendant argued that the trial court erred in concluding that he was not intellectually disabled. The Supreme Court remanded the case to the trial court to hold a new hearing to determine whether Defendant was intellectually disabled in accordance with the criteria set forth in this opinion, holding (1) the trial court should have discussed evidence presented on the Flynn Effect, although it was in the trial court's discretion whether to include it as a factor in Defendant's IQ scores; (2) the trial court used the wrong standard in finding that Defendant did not have significant limitations in his adaptive skills; (3) the holding in State v. Lott, 779 N.E.2d 1011 (Ohio 2002), that there is a rebuttable presumption that a defendant is not intellectually disabled if his IQ score is above 70 is no longer valid; and (4) for purposes of eligibility for the death penalty, a court determining whether a defendant is intellectually disabled must consider three core elements set forth in this opinion. View "State v. Ford" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the court of common pleas concluding that the Streetsboro Planning and Zoning Commission acted arbitrarily and capriciously by denying Appellant's application for a conditional-use permit, holding that that court of appeals exceeded its scope of review in this case.Finding that Appellant's expert lacked credibility, the Commission determined that Appellant did not establish by clear and convincing evidence that Appellant's proposed conditional use met the relevant standards outlined in the relevant ordinances. The court of appeals pleas determined that the Commission's denial of the application was arbitrary and capricious. The court of appeals reversed, holding that the Commission could have justifiably concluded that Appellant's expert lacked credibility. The Supreme Court reversed, holding that the court of appeals had no authority to second-guess the court of common pleas' decision on questions going to the weight of the evidence supporting the Commission's findings. View "Shelly Materials, Inc v. City of Streetsboro Planning & Zoning Commission" on Justia Law

The Supreme Court held that where Defendant was previously convicted of child endangering in connection with the death of his child and then, after his release from prison, Defendant told authorities that he had beaten his son to death, the prohibition against double jeopardy did not prevent the state from prosecuting Defendant for murder or aggravated murder.Defendant originally told authorities that he had accidentally caused his son's death while driving an ATV. Defendant was charged with child endangering and involuntary manslaughter. Defendant entered into a plea agreement whereby he pled guilty to child endangering, and the involuntary manslaughter charge was dismissed. After Defendant served his time in prison, he confessed that he had beaten the child to death and fabricated the ATV accident. Defendant was then indicted for aggravated murder and murder. Defendant filed a motion to dismiss the murder charges, asserting that involuntary manslaughter is a lesser included offense of murder and aggravated murder and that the state was thus barred from prosecuting the charges. The trial court denied the motion. The court of appeals reversed. The Supreme Court reversed, holding that double jeopardy principles did not bar Defendant's prosecution. View "State v. Soto" on Justia Law

The Supreme Court affirmed the two judgments arising out of the same underlying criminal case, holding that Appellant's requested writ of mandamus was properly denied, and Appellant's complaint for a writ of habeas corpus was properly dismissed.Appellant pleaded guilty to murder, but the sentencing entry incorrectly stated that Appellant had pleaded guilty to aggravated murder. The presiding judge subsequently journalized a nunc pro tunc sentencing entry to clarify that Appellant had pleaded guilty to murder rather than aggravated murder. The court of appeals then affirmed the conviction and sentence. Appellant later filed a complaint for writ of mandamus claiming that the trial court lacked jurisdiction to issue the nunc pro tunc entry. The court of appeals concluded that Appellant's claim was barred by res judicata and that he had an adequate remedy at law. Appellant also filed a complaint for a writ of mandamus arguing that he was entitled to release because the trial court failed to require a written waiver of a jury trial. The court of appeals dismissed the complaint. The Supreme Court affirmed both judgments, holding that Appellant was not entitled relief in mandamus and that his habeas complaint was properly dismissed. View "State ex rel. Parker v. Russo" on Justia Law

The Supreme Court denied a writ of prohibition sought by C.H. to bar Respondents, Cuyahoga County Juvenile Court Judge Jennifer L. O'Malley and her designated magistrate, from exercising jurisdiction over a case involving the custody of C.H.'s biological grandchild, holding that Respondents had jurisdiction over the pending action.The child in this custody dispute was removed from the home of his adoptive mother, C.H., in Arizona and placed in temporary emergency custody of Cory Osley, who claimed to be the child's biological father and filed an application to determine the custody of the child in the Cuyahoga County Court of Common Pleas, Juvenile Division. C.H. challenged Ohio's jurisdiction over the case and asked that the child be returned to the custody of C.H. The magistrate ordered that the Ohio court had jurisdiction over the child's immediate well being and ordered the child to remain in Osley's temporary emergency custody. C.H. then commenced this action for a writ of prohibition. The Supreme Court denied the writ, holding that Ohio was the child's home state when Osley filed the pending custody application, and therefore, Respondents had jurisdiction in this matter. View "C.H. v. O'Malley" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's request for a writ of mandamus ordering the Tuscarawas County Board of Elections to certify Appellant's name to the November 2019 ballot as a candidate for mayor of the village of Sugarcreek, holding that Appellant did not have a clear legal right to have his name placed on the November ballot where his petition did not substantially comply with Ohio Rev. Code 3513.261.The Board rejected Appellant's petition because he failed to complete the nominating-petition portion of the Form No. 3-O part-petitions. The court of appeals denied Appellant's complaint seeking a writ of mandamus ordering the Board to certify his name to the ballot. The Supreme Court affirmed, holding (1) Appellant's submission of Form No. 3-O part-petitions that omitted his name and the office he sought from the nominating-petition portion of the forms did not amount to substantial compliance with section 3513.261. View "State ex rel. Weller v. Tuscarawas County Board of Elections" on Justia Law

The Supreme Court denied a writ of prohibition sought by Bryan R. Barney and Walbonns, LLC (the protestors) seeking to prevent the Union County Board of Elections from placing a township zoning referendum on the November 5, 2019 general election ballot, holding that the Board correctly denied the protest.At issue was the decision of the Board determining that a petition seeking to place a referendum concerning a zoning amendment on the November ballot contained a sufficient number of valid signatures and certifying the issue to the ballot. The protestors filed a complaint for a writ of prohibition, arguing that the Board lacked authority to place the petition on the ballot. The Supreme Court disagreed, holding that the petition met the statutory requirements and that the Board correctly rejected the protestors' arguments for invalidating the petition. View "State ex rel. Barney v. Union 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 mandamus to compel the court of common pleas judge to resentence him, holding that Appellant had an adequate remedy at law by way of appeal.Appellant was convicted of the rape of and gross sexual imposition on a child less than thirteen years of age. Appellant later filed a complaint for a writ of mandamus arguing that his sentence was void because the trial court failed properly to notify him of his post release control and abused its discretion in sentencing him to a definite term of life imprisonment. The court of appeals dismissed the complaint, concluding that res judicata barred Appellant's arguments. The Supreme Court affirmed, holding (1) the court of appeals erred when it dismissed Appellant's mandamus claim on res judicata grounds; but (2) Appellant had an adequate remedy of law by way of appeal, and therefore, Appellant was not entitled to mandamus relief. View "State ex rel. Green v. Wetzel" on Justia Law

The Supreme Court granted Appellant's motion for reconsideration and vacated its decision in State v. Braden, __ N.E.3d __ (Ohio 2018) (Braden I), holding that Ohio Rev. Code 2947.23(C) grants a sentencing court jurisdiction to waive, suspend, or modify the payment of the costs of prosecution imposed prior to the statute's effective date.In Braden I, the Supreme Court held that the General Assembly did not expressly make section 2947.23(C) retroactive and that, with respect to costs imposed before the statute's enactment, the trial court lacked jurisdiction to reconsider its own final order. The Court then granted Appellant's motion for reconsideration and vacated its decision in Braden I, holding that neither section 2947.23(C) nor this Court's precedent precludes trial courts from waiving, suspending, or modifying court costs imposed before the effective date of section 2947.23(C). View "State v. Braden" on Justia Law