Justia Criminal Law Opinion Summaries

Ricardo Dodson is serving prison sentences for convictions in two separate cases. In the first case, Dodson was indicted on multiple counts of rape, attempted rape, and kidnapping. The jury returned guilty verdicts, but the jury-verdict forms mistakenly listed his surname as Jackson instead of Dodson. The trial-court judge read the wrong name into the record and sentenced Dodson to consecutive prison terms for each count. In the second case, Dodson was indicted on another count of rape and kidnapping. He was found guilty and sentenced to serve this sentence consecutively to the sentences from the first case, even though he had not yet started serving those sentences.Dodson petitioned the Seventh District Court of Appeals for a writ of habeas corpus, arguing that the mistyping of his surname on the jury-verdict forms stripped the trial court of jurisdiction and that the sentences imposed were ambiguous. He claimed that the sentence in the first case should be considered concurrent due to the lack of specificity in the sentencing entry and that the sentence in the second case was ambiguous because it referred to a sentence "already being served" when he had not yet started serving the first sentence.The Seventh District Court of Appeals dismissed Dodson’s petition, determining that his claims were not cognizable in habeas corpus. The court found that the alleged errors did not affect the trial court’s jurisdiction and that Dodson had an adequate remedy in the ordinary course of law through direct appeal. Dodson appealed to the Supreme Court of Ohio.The Supreme Court of Ohio affirmed the Seventh District’s judgment, holding that the trial court had jurisdiction over Dodson’s case and that the sentencing entries were not ambiguous. The court concluded that Dodson’s arguments could have been addressed through direct appeal and did not warrant habeas corpus relief. View "State ex rel. Dodson v. Smith" on Justia Law

Jadyn Logan was convicted of aggravated robbery in January 2018, a first-degree felony that prohibited her from possessing a firearm under R.C. 2923.13(A)(2). Later, a Cuyahoga County grand jury indicted her for having weapons while under a disability, improperly handling firearms in a motor vehicle, and carrying a concealed weapon. Logan pleaded guilty to attempting to have weapons while under a disability with a one-year firearm specification, and the other charges were dismissed. The trial court sentenced her to one year for the firearm specification and two years of community control for the attempt offense.The State appealed to the Eighth District Court of Appeals, arguing that R.C. 2929.13(F)(8) required a prison term for the attempt offense. The Eighth District affirmed the trial court's decision, holding that the statute required a prison sentence only for the firearm specification, not the underlying felony offense. The State sought en banc consideration, which was denied, and the Eighth District maintained its position.The Supreme Court of Ohio reviewed the case and determined that R.C. 2929.13(F)(8) mandates a prison sentence for any felony offense with a corresponding firearm specification. The court clarified that a firearm specification is a sentencing enhancement, not a separate offense, and that the statute's language requires a prison term for the underlying felony offense when a firearm specification is attached. The court reversed the Eighth District's judgment and remanded the case to the trial court for resentencing consistent with this interpretation. View "State v. Logan" on Justia Law

James P. Ellis, an inmate at Marion Correctional Institution, has been incarcerated since his 1995 convictions for aggravated burglary and aggravated murder. He contends that the Ohio Adult Parole Authority unlawfully corrected an error in his sentencing entry and has been using this correction in his parole hearings. Ellis sought a writ of prohibition from the Tenth District Court of Appeals to prevent the parole authority from conducting future parole screenings and to compel it to contact the sentencing court for corrective procedures.The Tenth District Court of Appeals dismissed Ellis's complaint. The court reasoned that Ellis did not sufficiently demonstrate that the parole authority lacked jurisdiction or relied on erroneous information. Additionally, the court noted that compelling the parole authority to contact a court is beyond the scope of relief provided by a writ of prohibition.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District's dismissal. The court held that the parole authority has jurisdiction to hold parole proceedings for all parole-eligible inmates, including Ellis. The court found that Ellis's parole eligibility is determined by statute, and the parole authority's actions were authorized by law. Consequently, Ellis failed to prove the elements required for a writ of prohibition. The court also noted that Ellis's request to compel the parole authority to contact the sentencing court was not appropriate for a writ of prohibition, which is typically used to prevent unauthorized actions rather than to compel specific actions. View "State ex rel. Ellis v. Adult Parole Auth." on Justia Law

Niquan M. Dunn was indicted on six counts in the Geauga County Common Pleas Court, including drug-related crimes and possession of criminal tools. Counts 2 and 4, relevant to this appeal, charged Dunn with aggravated trafficking in drugs and trafficking in cocaine, respectively, with enhancements for committing the crimes "in the vicinity of a juvenile." The case proceeded to trial, where the State presented evidence including testimony from detectives and a controlled buy operation. Drugs and drug paraphernalia were found in a house where Dunn was staying, and a four-month-old child was present in the home.The trial court denied Dunn's motion for acquittal on Counts 1 through 5 and the jury found him guilty on those counts. Dunn was sentenced to a total of 36 months in prison. On appeal, the Eleventh District Court of Appeals reversed the convictions in part, finding insufficient evidence that Dunn committed the crimes in the vicinity of a juvenile, as required for the enhancement. The appellate court focused on the lack of direct evidence that the child was present during the drug activities and distinguished the case from prior decisions.The Supreme Court of Ohio reviewed the case and held that the evidence was sufficient to support the "in the vicinity of a juvenile" enhancement. The court emphasized that circumstantial evidence and reasonable inferences drawn from the evidence could lead a reasonable juror to conclude that the child was present when Dunn prepared the drugs for distribution. The court reversed the Eleventh District's judgment, reinstating the enhancement on Count 2. View "State v. Dunn" on Justia Law

Thomas Reese, the petitioner, sought a writ of habeas corpus for his release from Trumbull Correctional Institution, arguing that he had completed his sentence. Reese was convicted in 2002 on multiple charges, including felonious assault and attempted murder, and was sentenced to a total of 25 years in prison. However, the sentencing entry contained errors, including an incorrect calculation of the total sentence and the improper merging of counts.Reese did not raise these sentencing issues in his direct appeal, which focused solely on the trial court's alleged failure to comply with statutory requirements before accepting his jury trial waiver. The court of appeals reversed his convictions, but the Supreme Court of Ohio reinstated them. In 2023, Reese attempted to correct the sentencing entry through a motion, which was denied by the trial court. The court of appeals affirmed the denial, acknowledging the errors but stating they were voidable and could have been addressed on direct appeal. The Supreme Court of Ohio declined to accept Reese's jurisdictional appeal.Reese filed for habeas corpus in 2024, arguing that his sentence should be calculated as 23 years, considering the errors in the sentencing entry and his jail-time credit. The Supreme Court of Ohio agreed with Reese, noting that the sentencing entry indicated a 23-year sentence, and Reese had served this time. The court found that Reese was entitled to immediate release, rejecting the warden's arguments that the claim was barred by res judicata and that sentencing errors were not jurisdictional. The court granted the writ of habeas corpus, ordering Reese's release. View "Reese v. Davis" on Justia Law

In 1980, Delmar Hickman was arrested for the murder of his parents and later pled not guilty by reason of insanity. He was committed to a mental-health facility and has been continuously hospitalized since then. Recently, the managing officer of his current facility recommended that Hickman be granted conditional release to a nonsecured group home. The Ashtabula County Court of Common Pleas disapproved this recommendation.The Eleventh District Court of Appeals affirmed the trial court’s judgment. Hickman appealed to the Supreme Court of Ohio, arguing that a trial court has no discretion to deny a change in commitment in the absence of clear and convincing evidence indicating that the level change should not be granted.The Supreme Court of Ohio reviewed the case and held that under R.C. 2945.401, a trial court must use its discretion to approve, disapprove, or modify a recommendation for a change to nonsecured status or termination of commitment after considering all relevant factors, including those listed in R.C. 2945.401(E)(1) through (6). The court found that the trial court did not abuse its discretion in disapproving the recommendation for Hickman’s conditional release, given his history of severe violence and the potential threat to public safety if he were released to a nonsecured environment. The Supreme Court of Ohio affirmed the judgment of the Eleventh District Court of Appeals. View "State v. Hickman" on Justia Law

Jaidee Miree and Desmond Duncan were charged with murder, involuntary manslaughter, felonious assault, and other offenses related to the death of Ramses Hurley on June 16, 2019. The incident occurred during an attempted robbery where Hurley was picked up under the pretense of a drug deal. A struggle ensued, shots were fired, and Hurley was ejected from the moving vehicle, resulting in his death from blunt-force trauma. At trial, conflicting testimonies were presented regarding who initiated the violence and whether Hurley had a gun.The trial commenced in June 2021, and the trial court instructed the jury on self-defense using the preamendment version of R.C. 2901.09, which included a duty to retreat. Miree and Duncan were found guilty of felony murder, felonious assault, and other charges, and were sentenced to 15 years to life in prison. They appealed, arguing that the trial court should have applied the amended version of R.C. 2901.09, effective April 6, 2021, which eliminated the duty to retreat.The Eighth District Court of Appeals upheld the trial court's decision, ruling that the amendment to R.C. 2901.09 was substantive and could not be applied retroactively to offenses committed before its effective date. A dissenting judge argued that the amendment should apply to all trials after its effective date.The Supreme Court of Ohio reviewed the case and affirmed the Eighth District's decision. The court held that the amendment to R.C. 2901.09, which eliminated the duty to retreat, did not apply retroactively to acts of self-defense that occurred before the amendment's effective date. The court concluded that the trial court correctly applied the former version of the statute, and the judgment of the Eighth District Court of Appeals was affirmed. View "State v. Miree" on Justia Law

Chelsie Kennedy pled guilty to robbery charges in three different cases in the Franklin County Court of Common Pleas. She received an aggregate nine-year sentence in one case, a five-year sentence in another case to be served consecutively to the first, and a six-year sentence in a third case to be served concurrently with the second but consecutively to the first. Kennedy filed motions for judicial release in the latter two cases, arguing she was eligible based on the aggregate of her sentences.The trial court granted Kennedy's motions for judicial release in the two cases, finding her to be an eligible offender under R.C. 2929.20(B) and (C)(4) and (5). The court noted that Kennedy had served more than eight years in prison and considered her conduct in prison and the seriousness and recidivism factors. The court suspended her sentences in the two cases and placed her on community control for three years, to begin after completing her sentence in the first case. The State appealed, arguing that Kennedy had not completed her nine-year sentence in the first case and that judicial release eligibility should be determined separately for each stated prison term.The Supreme Court of Ohio reviewed the case and concluded that judicial-release eligibility is determined separately for each stated prison term, informed by the aggregate of all nonmandatory prison terms imposed. The court found that the lower courts did not conduct a complete inquiry into whether Kennedy had served the requisite amount of her stated prison terms before filing her motion for judicial release. The Supreme Court reversed the judgment of the Tenth District Court of Appeals and remanded the case to the trial court for further proceedings to determine whether Kennedy completed the prescribed waiting period. View "State v. Kennedy" on Justia Law

Quantez Wilcox met his ex-girlfriend, Doniesha Monroe, near a public library in Cincinnati. During their conversation, Monroe's boyfriend, Keshawn Turner, approached and argued with Monroe. Wilcox, believing Turner was reaching for a gun, shot Turner, who later died. Wilcox fled but was soon stopped and arrested by police. Meanwhile, Monroe identified Wilcox as the shooter to a police officer, whose body camera recorded the interaction. Monroe also mentioned past bad acts by Wilcox after learning he was apprehended.The trial court admitted the body-camera footage into evidence despite Wilcox's objection, arguing it violated his right to confrontation since Monroe did not testify in court. Wilcox was convicted of multiple felonies, including murder. The First District Court of Appeals affirmed some convictions but reversed the murder conviction, ruling that Monroe's statements were testimonial and their admission violated Wilcox's confrontation rights. The court ordered a new trial for the murder charge.The Supreme Court of Ohio reviewed whether the admission of Monroe's statements violated Wilcox's confrontation rights. The court determined that Monroe's initial statements were nontestimonial as they were made during an ongoing emergency. However, statements made after Wilcox's apprehension were testimonial. The court reversed the First District's decision regarding the initial statements and remanded the case to determine their admissibility under the Ohio Rules of Evidence and to conduct a harmless-error analysis. View "State v. Wilcox" on Justia Law

In this case, the defendant, Garry Smith, was indicted on two counts of domestic violence for an incident on March 21, 2020, involving his pregnant fiancée, B.B. Smith pleaded not guilty and filed a motion to exclude B.B.'s statements recorded on police body cameras, arguing it would violate his right to confrontation. The trial court initially denied the motion but reserved its final ruling. During the bench trial, B.B. did not appear, and the State presented evidence including body-camera footage capturing B.B.'s statements to police and EMTs.The trial court admitted the body-camera footage, ruling B.B.'s statements were nontestimonial and fell under the excited utterance hearsay exception. Smith was found guilty and sentenced accordingly. On appeal, the Eighth District Court of Appeals reversed the trial court's decision, finding that B.B.'s statements to the police were testimonial and their admission violated Smith's confrontation rights. The appellate court did not address Smith's hearsay challenge or the weight of the evidence due to its dispositive ruling on the confrontation issue.The Supreme Court of Ohio reviewed the case to determine if the admission of B.B.'s statements violated Smith's confrontation rights. The court held that B.B.'s statements to the police officer were testimonial because they were made to further the officer's investigation of a past crime, not to address an ongoing emergency. However, B.B.'s statements to the EMTs were deemed nontestimonial as they were made for the purpose of receiving medical care.The Supreme Court of Ohio reversed the appellate court's judgment regarding Smith's convictions for the March 21, 2020 incident and remanded the case to the Eighth District to determine the admissibility of B.B.'s statements to the EMTs under hearsay rules, conduct a harmless-error analysis, and address Smith's remaining assignments of error as necessary. View "State v. Smith" on Justia Law