Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Ohio
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Thomas E. Knuff Jr. was convicted on two counts of aggravated murder with death specifications for killing John Mann and Regina Capobianco. Knuff was released from prison and arranged to stay with Mann. After his release, he began staying at a motel, paid for by a former prison employee, Alicia Stoner, with whom he had a relationship while incarcerated. When his parole officer discovered he was not living at the motel as he claimed, he moved in with Mann. Mann was not living alone; Regina Capobianco also lived there. Knuff and Capobianco had a complicated relationship, and conflict arose between them, which led to the murders.The Supreme Court of Ohio affirmed Knuff's convictions and the imposition of the death sentences, finding that none of the 24 arguments that he presented justified a reversal. Among other things, the court found that the trial court did not err in denying Knuff’s motion for self-representation, which was made just eight days before jury selection began. The court also rejected Knuff’s claim that the trial court improperly restricted his counsel’s voir dire questioning, thereby denying him a meaningful, constitutionally adequate voir dire. The court additionally found that the trial court did not err in overruling Knuff’s challenges for cause of various jurors, or in granting the prosecution's for-cause challenges.The court also found that the trial court's error in giving the jury a duty-to-retreat instruction was harmless beyond a reasonable doubt. The court rejected Knuff’s claim that the jury’s finding of guilt for the aggravated-murder counts, felony-murder specifications, and underlying felony offenses was based on insufficient evidence and that his convictions for those offenses were against the manifest weight of the evidence. View "State v. Knuff" on Justia Law

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In this case, Robert Plaza, a prisoner serving an indeterminate sentence, appealed the dismissal of his petition for a writ of habeas corpus by the Ninth District Court of Appeals. Plaza's petition related to the Adult Parole Authority's decision to revoke his parole. He argued that he was denied a preliminary hearing to determine if there was probable cause to believe he had violated parole conditions, that he was denied due process of law, and that he should be immediately released.The Court of Appeals dismissed the petition based on territorial jurisdiction, as Plaza had been moved to a different correctional institution outside of its jurisdiction during the proceedings. However, Plaza argued that he had been transferred back to the original jurisdiction before the dismissal of his petition, and therefore, the Court of Appeals had erred.The Supreme Court of Ohio agreed with Plaza that the dismissal based on territorial jurisdiction was incorrect. However, the court found that Plaza's allegations did not state a claim cognizable in habeas corpus. The court noted that habeas corpus is a remedy for a due-process violation only in extreme circumstances involving unreasonable delay, which was not alleged by Plaza. The court stated that the usual remedy for such a violation is a writ of mandamus compelling a second hearing, not a release from custody. Therefore, the court affirmed the dismissal of Plaza's petition on alternative grounds. View "Plaza v. Black" on Justia Law

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This case originates from the Supreme Court of Ohio and concerns a defendant, Tyler Wilson, who was charged with attempted murder and felonious assault. The charges stemmed from an altercation at a gas station where Wilson fired a gun out his car window to scare off the other party involved in the dispute. Wilson claimed he acted in self-defense, but the trial court determined that he was not entitled to a self-defense jury instruction because he did not intend to harm or kill the other party. Wilson was found guilty of felonious assault, but not attempted murder.On appeal, the Supreme Court of Ohio reversed the lower court’s decision, ruling that an individual does not need to intend to harm or kill another person to be entitled to a self-defense jury instruction in a criminal trial. The court found that Wilson’s testimony supported the intent element for self-defense and that his trial counsel was ineffective by failing to request a self-defense jury instruction. As such, the court vacated Wilson’s conviction and remanded the case back to the trial court for further proceedings. View "State v. Wilson" on Justia Law

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In this case, the Supreme Court of Ohio addressed the issue of the filing deadline for a petition for postconviction relief following a delayed appeal. The defendant was convicted of murder and other crimes, did not file a direct appeal within the required 30 days but later filed a motion for a delayed appeal, which was granted. He filed a petition for postconviction relief within 365 days of the trial transcript being filed in the court of appeals.The court of appeals had affirmed the trial court's judgment, asserting that the defendant's petition was untimely. They argued that in the case of a delayed appeal, the applicable deadline was not the direct-appeal deadline of 365 days from the date of the filing of the trial transcript but rather the no-appeal-taken deadline of 365 days from the expiration of the time for filing a direct appeal.The Supreme Court of Ohio disagreed, holding that under Ohio law, a delayed appeal of a conviction is a direct appeal, and the same postconviction-relief deadline applies for a delayed appeal as applies to any other type of direct appeal. The court found that the defendant had timely filed his postconviction petition within 365 days after the transcript was filed in the court of appeals in his delayed appeal. Therefore, the Supreme Court of Ohio reversed the judgment of the Eighth District Court of Appeals and remanded the matter to that court for further consideration. View "State v. Dudas" on Justia Law

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In a case before the Supreme Court of Ohio, the defendant was accused of setting up a fake car sale, during which he threatened two women with a gun and stole money. The defendant was convicted of robbing both women and illegally possessing a firearm. On appeal, the First District Court of Appeals overturned these convictions, arguing that the defendant could not be convicted of robbing the woman who was not directly holding the money. Furthermore, the court held that the defendant's rights were violated when the state used information at trial that was not previously disclosed to the defense.The Supreme Court of Ohio reversed the lower court's decision. Firstly, the court clarified that under the state's robbery statute, a person can be convicted of robbery if they commit a theft offense and threaten physical harm to another person, even if the person threatened is not the same as the theft victim. As such, both women were properly considered as victims of robbery. Secondly, the court determined that the defendant had forfeited his claim to a violation of his rights, as he failed to raise the issue of undisclosed evidence at the trial level.The case was remanded back to the First District Court of Appeals to consider the defendant's remaining assignments of error. View "State v. Brown" on Justia Law

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In the case of State v. Nicholson, the Supreme Court of Ohio affirmed the defendant's convictions and death sentences for the aggravated murders of two individuals. The court found that the evidence was sufficient to support the convictions, as it demonstrated that the defendant acted with prior calculation and design. Additionally, the court found no error in the trial court's decision to admit certain evidence, such as photographs from the crime scene and testimonies about the defendant's relationships with the victims. Furthermore, the court rejected the defendant's arguments regarding the adequacy of the jury instructions and the admission of victim-impact evidence, among other issues. The court concluded that the defendant did not establish any grounds for reversal of his convictions or sentences. View "State v. Nicholson" on Justia Law

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In this case, the Supreme Court of Ohio considered whether a juvenile, T.D.S., knowingly, intelligently, and voluntarily waived his Miranda rights before providing statements to the police. The statements related to a homicide investigation involving another juvenile.The case originated from an incident in 2019, where the Police responded to a report of shots fired in an apartment building and discovered a male juvenile, S.G., with gunshot wounds. The police investigation led them to T.D.S., who was then 15 years old. During questioning at T.D.S.'s mother’s house, T.D.S. initially denied involvement in the shooting but later admitted to accidentally shooting S.G. while playing with a gun. After these statements, T.D.S. was read his Miranda rights and questioned further. He was subsequently charged with several offenses including murder and felonious assault.T.D.S. argued that the juvenile court should have granted a motion to suppress all the statements he made to the police officers, contending that he did not knowingly, intelligently, and voluntarily waive his Miranda rights. After considering the totality of the circumstances, including T.D.S.'s age, prior criminal experience, and the nature of the police interrogation, the Supreme Court of Ohio affirmed the lower courts' decisions that T.D.S. had knowingly, intelligently, and voluntarily waived his Miranda rights. The court found that the police did not engage in coercion and that T.D.S.'s waiver was not involuntary.T.D.S. also argued that his post-Miranda statements should be presumed inadmissible under the court's previous reasoning in a case called State v. Farris. However, the court found that T.D.S. had not properly raised this argument in the lower courts, so it was forfeited. Even if he had preserved the argument, the court found that the record did not support his claims under the Farris case.Therefore, the court affirmed the judgment of the lower courts, finding that T.D.S.'s post-Miranda statements were properly admitted at trial. View "In re T.D.S." on Justia Law

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In December 2019, a taxicab driver, Phillip Palmer, shot a heavily intoxicated passenger, Nicholas Young, following a dispute over cab fare. The incident escalated into a physical altercation at a gas station, where Young shoved Palmer twice, causing him to fear for his life. Palmer, who had begun carrying a gun in his cab after hearing about a driver who had been shot by a passenger, fired two shots at Young, hitting him in the neck. Young survived his injuries. At trial, Palmer admitted to the shooting but claimed self-defense. The trial court denied Palmer's request for a self-defense jury instruction, finding Palmer's statements about his means of escape not credible and determining that a reasonable person would not have believed they were in danger of being killed by Young under the circumstances. Palmer was acquitted of attempted murder but found guilty of felonious assault and a firearm specification.The Supreme Court of Ohio reversed the decision of the Twelfth District Court of Appeals, which had affirmed the trial court's judgment. The Supreme Court determined that the trial court had improperly weighed the evidence when performing a sufficiency analysis. The court found that Palmer had presented legally sufficient evidence for each element of self-defense and was therefore entitled to a self-defense jury instruction. The evidence presented, if believed, could convince a trier of fact that Palmer was acting in self-defense. Therefore, the case was remanded for a new trial on the felonious-assault charge and accompanying firearm specification. View "State v. Palmer" on Justia Law

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The case involves appellant Soleiman Mobarak, who appealed the judgment of the Tenth District Court of Appeals dismissing his petition for a writ of mandamus against appellee, Franklin County Court of Common Pleas Judge Jeffrey M. Brown. Mobarak had sought to vacate his criminal convictions for lack of subject-matter jurisdiction in the trial court. The court of appeals held that the trial court had jurisdiction over Mobarak’s criminal case and that Mobarak had an adequate remedy in the ordinary course of the law.In 2012, Mobarak was indicted on charges of engaging in a pattern of corrupt activity, aggravated trafficking in drugs, and aggravated possession of drugs. The charges alleged that Mobarak had possessed and sold a controlled-substance analog commonly known as bath salts. In his petition, Mobarak asserted that the trial court lacked subject-matter jurisdiction over his criminal case on several grounds including that there was no statute prohibiting the possession or sale of bath salts at the time his offenses were alleged to have occurred, and that the controlled-substance-analogs law was unconstitutionally vague.The Supreme Court of Ohio affirmed the Tenth District Court of Appeals' judgment dismissing Mobarak’s petition. The court held that Mobarak’s petition failed to state a mandamus claim because he had an adequate remedy in the ordinary course of the law and failed to show that the trial court had patently and unambiguously lacked jurisdiction over his criminal case. The court found that by virtue of the Ohio Constitution and R.C. 2931.03, the trial court had jurisdiction over Mobarak’s criminal case. The court also noted that Mobarak’s arguments were similar to those raised and rejected in his prior appeals. The court stated that extraordinary writs may not be used as a substitute for an otherwise barred second appeal or to gain successive appellate reviews of the same issue. View "State ex rel. Mobarak v. Brown" on Justia Law

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The case involves an appeal by an inmate, Keith Walker, against the Third District Court of Appeals' dismissal of his request for a writ of mandamus. Walker had been convicted of misdemeanor domestic violence in 2020, for which he received the maximum sentence allowed by law. He later filed a motion to vacate his guilty plea, arguing that the plea and the judgment of conviction were void due to the absence of a judge at his plea hearing, and the prosecutor's alleged role in accepting his plea and sentencing him. The municipal court judge, Teresa Ballinger, denied his motion. Walker then filed a complaint for a writ of mandamus, asking that his conviction be vacated as an illegal and void judgment. This was dismissed by the Third District Court of Appeals, who agreed with Judge Ballinger's argument that Walker had failed to submit an affidavit required by R.C. 2969.25(A), and that his claim was not cognizable in mandamus.On appeal, the Supreme Court of Ohio held that the Third District Court of Appeals was incorrect to dismiss the action based on a failure to comply with R.C. 2969.25(A)’s affidavit requirement, as the statute does not require a statement that the inmate has filed no such civil action or appeal. However, the Supreme Court agreed with the lower court's determination that Walker's claim was not cognizable in mandamus, as his argument essentially raised a nonjurisdictional defect for which he had an adequate remedy in the ordinary course of law. Therefore, the Supreme Court affirmed the judgment of the Third District Court of Appeals dismissing Walker's complaint. View "State ex rel. Walker v. Ballinger" on Justia Law