Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Ohio
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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that there is a rebuttable presumption that a defendant is not intellectually disabled if his IQ score is above 70 is no longer valid; and (4) for purposes of eligibility for the death penalty, a court determining whether a defendant is intellectually disabled must consider three core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

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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

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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

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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

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The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the trial court overruling Defendant's motion to suppress evidence relating to a traffic stop, holding that the arresting officer had reasonable suspicion to make an investigatory stop. In affirming the trial court, the court of appeals determined that the discrepancy between the color in the vehicle's registration and the actual color of the vehicle was sufficient to raise the officer's suspicion to that vehicle was either stolen or that the license plate had been taken from another vehicle. The Supreme Court affirmed, holding that when a police officer encounters a vehicle that is painted a different color from the color listed in the vehicle registration records and the officer believes that the vehicle or its license plates may be stolen, the officer has a reasonable, articulable suspicion of criminal activity and is authorized to perform an investigative traffic stop. View "State v. Hawkins" on Justia Law

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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

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The Supreme Court affirmed the judgment of the court of appeals granting the writ of mandamus sought by Appellant concerning certain public records Appellant had requested but denied the writ concerning others, holding that because Appellant did not comply with Ohio Rev. Code 149.43(B)(8) Cleveland Police Forensic Laboratory (CPFL) had no clear legal duty to produce the records identified in the first part of Appellant's request. The court of appeals denied the writ as to the first part of Appellant's request, determining that Appellant had not obtained court approval before requesting public records concerning a criminal investigation or prosecution, as he was required to do under Ohio Rev. Code 149.43(B)(8). The court noted that section 149.43(B) did not apply to the second part of Appellant's request, which did not seek records concerning a criminal investigation or prosecution. The Supreme Court affirmed, holding that because Appellant did not obtain court approval as required by section 149.43(B)(8), the court of appeals properly denied the first part of his request. View "State ex rel. Ellis v. Cleveland Police Forensic Laboratory" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals denying Appellant's request for a writ of mandamus and granting summary judgment in favor of Appellee, Cuyahoga County Court of Common Pleas Judge Pamela Barker, holding that Appellant's three propositions of law lacked merit. In 2014, Appellant was found guilty of aggravated murder and other crimes. Judge Barker sentenced Appellant. In 2018, Judge Barker granted in part Appellant's motion to correct a facially illegal sentence and entered a nunc pro tunc entry clarifying that the firearm specifications had been merged for sentencing. Thereafter, Appellant filed a complaint in mandamus seeking to compel Judge Barker to vacate both he 2014 sentencing order and the 2018 nunc pro tunc entry and to repentance him, claiming that certain errors rendered the 2014 sentencing enter void. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant failed to establish that she was entitled to a writ of mandamus. View "State ex rel. Rodriguez v. Barker" on Justia Law

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The Supreme Court affirmed the judgments in these consolidated appeals, holding that the court of appeals properly dismissed Appellant's complaint for a writ of habeas corpus as well as Appellant's complaint for a writ of mandamus. Appellant was convicted of two counts of rape and kidnapping. Appellant filed a petition for a writ of habeas corpus arguing that he was entitled to habeas relief on the rape sentences because he had completed the maximum term for those convictions. The court of appeals dismissed the petition for failure to state a claim. Appellant also filed a petition for a writ of mandamus claiming that his kidnapping sentence exceeded date statutory maximum and that his sentence therefore should be modified. The court of appeals dismissed the petition for failure to state a claim. The Supreme Court affirmed, holding that the court of appeals (1) properly dismissed Appellant's petition for a writ of habeas corpus, and (2) correctly dismissed Appellant's mandamus action for failure to state a claim. View "State ex rel. Norris v. Wainwright" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals granting summary judgment in favor of Appellees and denying Appellant's petition for a writ of mandamus, holding that Appellant failed to establish that he was entitled to a writ of mandamus. Appellant was found guilty of engaging in a pattern of corrupt activity and other offenses. Appellant later filed his petition for a writ of mandamus claiming that the indictment had failed to place him on notice of the predicate offenses underlying the charges and failed to charge essential elements of the underlying predicate offenses. The court of appeals denied the petition, holding that Appellant's claims were barred by res judicata. The Supreme Court affirmed, holding that even if the court of appeals erred in granting the summary judgment motion based on res judicata, the court properly ruled in favor of Appellees because relief in mandamus is unavailable to challenge a defective indictment. View "State ex rel. Sands v. Culotta" on Justia Law