Justia Ohio Supreme Court Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals affirming the trial court's judgment dismissing Plaintiffs' claims for quiet title and declaratory judgment based on their contention that an oil and gas lease had terminated by its terms due to lack of production, holding that the twenty-one-year limitations period in Ohio Rev. Code. 2305.04 applied.In their complaint Plaintiffs alleged that the well at issue did not produce any oil or gas from its inception until 1999 and that the well had been inoperative for enough time to terminate the lease. Defendants asserted a statute of limitations defense to Plaintiffs' claims. The trial court held that Plaintiffs had not presented any evidence to satisfy their burden of proving that the well was no longer profitable and that Plaintiffs' claims were subject to a fifteen-year statute of limitations. Plaintiffs appealed, arguing that the correct limitations period was the twenty-one-year period under Ohio Rev. Code 2305.04. The court of appeals rejected the argument and affirmed the trial court's summary judgment for Defendants. The Supreme Court reversed, holding that the twenty-one-year statute of limitations period applied and that evidence of lack of production prior to 1999 was not irrelevant. View "Browne v. Artex Oil Co." on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that two sentencing statutes - Ohio Rev. Code 2925.041(C)(1) and 2929.14(A)(3)(b) - are in conflict and applying the rule of lenity to determine that Ohio Rev. Code 2929.14(A)(3)(b) and its lesser maximum penalty applies to violations of section 2925.041(A) when the drug in question is methamphetamine and the defendant has committed certain prior offenses, holding that section 2925.041(C)(1) applied to the defendant in this case. Defendant was convicted of one count of illegal assembly or possession of chemicals for the manufacture of methamphetamine, in violation of 2925.041(A). The trial court determined that section 2925.041(C)(1) applied and sentenced Defendant to a five-year prison term. The court of appeals reversed Defendant's sentence, holding that section 2929.14(A)(3)(b), the less punitive sentencing statute, applied. The Supreme Court reversed, holding that when a defendant is charged with a violation of section 2925.041(A) when the drug in question is methamphetamine and the defendant has committed certain prior offenses, the mandatory five-year sentence prescribed by section 2925.041(C)(1) is a special provision that prevails as an exception to the general statute, section 2929.14(A)(3)(b). View "State v. Pribble" on Justia Law

In this appeal from a criminal judgment the Supreme Court reversed the court of appeals' decision vacating some of Defendant's consecutive sentences and rendering Defendant's second assignment of error moot, holding that State v. Marcum, 59 N.E.3d 1231 (Ohio 2016), has no application to consecutive sentencing cases that are governed by Ohio Rev. Code 2953.08(G)(2).Defendant pleaded guilty to multiple offenses stemming from her act of stealing thousands of items from nursing home residents. Defendant waived her right to appeal including, but not limited to, the grounds listed in section 2953.08. The trial court imposed prison terms and ordered Defendant to serve the felony sentences consecutively. The court of appeals reviewed Defendant's sentence under Ohio Rev. Code 2929.11 and 2929.12 based on its reading of Marcum and determined that, while Defendant's consecutive sentences were appropriate and warranted the aggregate sentence was excessive and disproportionate. The Supreme Court reversed, holding (1) the State forfeited its argument that Defendant waived her right to appeal her sentence when it did not raise the issue at the court of appeals; and (2) the court of appeals should have analyzed Defendant's consecutive sentences for compliance with Ohio Rev. Code 2929.14(C)(4). View "State v. Gwynne" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus, holding that the court of appeals properly dismissed the complaint on the grounds that it failed to state a claim for habeas relief and was 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 habeas corpus, which the court of appeals dismissed. The Supreme Court affirmed, holding (1) none of Appellant's challenges to his convictions was cognizable in habeas corpus; and (2) the court of appeals also correctly determined that Appellant's claims were barred by res judicata. View "State ex rel. Kerr v. Turner" on Justia Law

The Supreme Court reversed the judgment of the court of appeals vacating the trial court's decision ordering Defendant, who pleaded guilty to cashing seven forged checks at branches of three different banks, to pay restitution to the banks in the amount of the forged checks, holding that a bank that cashes a forged check and then recredits the depositor's account is a victim to which the forger can be required to pay restitution.In reversing the trial court's judgment, the court of appeals determined that the banks were not "victims" for purposes of Ohio Rev. Code 2929.18, the statute authorizing a trial court to order an offender to pay restitution to a "victim" who suffers an economic loss, but were instead third parties who had reimbursed the account holders, who were the true victims. The Supreme Court reversed, holding that the banks were victims of Defendant's fraud that suffered an economic loss thereby, and therefore, the trial court properly ordered Defendant to pay restitution to the banks under section 2929.18. View "State v. Allen" on Justia Law

The Supreme Court dismissed Katrina D. Keith's claim seeking a writ of prohibition requiring the Lawrence County Board of Elections and its members (collectively, the Board) to remove Samuel T. Cramblit II's name from the ballot and prohibiting the Board from counting the votes Cramblit received as a candidate for the officer of Ironton Mayor in the November 5, 2019 general election, holding that Keith failed to state a claim in prohibition.Keith, Ironton's current mayor and Cramblit's opponent in the election, argued that the Board should not have certified Cramblit's name to the ballot because he did not meet the residency qualification for the office under Ironton's charter. The Supreme Court dismissed Keith's claim, holding that Keith failed to state a valid claim in prohibition because the Board did not exercise quasi-judicial power regarding Cramblit's candidacy. View "State ex rel. Keith v. Lawrence 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, holding that the court of appeals correctly held that Appellant failed fully to comply with Ohio Rev. Code 2969.25(C).In his petition, Appellant sought to compel a common pleas judge to hold a new sentencing hearing and to issue a final, appealable order in his criminal case. The court of appeals dismissed the petition for failure to state a claim, concluding that the petition was procedurally defective because the affidavit of indigence did not contain a statement of the balance in Appellant's inmate account and because Appellant an adequate remedy by law by way of direct appeal. The Supreme Court affirmed, holding that Appellant's failure to comply with the requirements of section 2969.25 required dismissal of his complaint. View "State ex rel. Sands v. Culotta" on Justia Law

The Supreme Court reversed the judgment of the court of appeals ruling that, pursuant to Ohio Rev. Code 2744.02(B)(1), a political subdivision may be liable for its negligent failure to train its police officers in high-speed pursuits, holding that the statute does not allow a political subdivision to be held liable for consequences arising from an employee's training or the supervision of that employee in operating a motor vehicle.A police officer was involved in a motor vehicle accident with a vehicle driven by Renee McConnell while the officer was responding to an emergency call. McConnell and her family brought suit against the officer, as well as the Coitsville Township and its board of trustees and the Coitsville Township Police Department (collectively, the Township), alleging that the Township negligently hired, trained, or supervised the officer. The trial court denied Defendants' motion for summary judgment asserting immunity. The court of appeals affirmed in part. The Supreme Court reversed, holding that the township was entitled to summary judgment on Plaintiffs' claim that the township was negligent, willful, and/or wanton in its hiring, policies, and/or training of the officer. View "McConnell v. Dudley" on Justia Law

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