Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Ohio

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The Supreme Court granted in part and denied in part Relator's request for a peremptory writ in mandamus seeking to compel responses to a request for public records, holding that Larry Greene, the public-records custodian for the Southern Ohio Correctional Facility, was required to provide Relator copies of requested pages of a legal-mail log, if they existed. Relator, an inmate, submitted a public-records request to Greene seeking a legal-mail log for February 27, 2019 and a copy of an envelope containing legal mail from the federal district court from that same date. Greene did not produce any documents. Relator then commenced this action for a writ of mandamus. The Supreme Court granted the motion in part and denied it in part, holding (1) because Greene did not dispute that if the institution maintained a log of incoming mail that log would qualify as a public record, Greene is ordered to provide the requested records; and (2) because the institution does not maintain the original envelopes enclosing incoming mail, Greene has no responsive documents to this request. View "State ex rel. McDougald v. Greene" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals and held that, unless otherwise authorized by statute, a trial court may not impose community-control sanctions on one felony count to be served consecutively to a prison term imposed on another felony count. Defendant pleaded guilty to three counts of unlawful sexual conduct with a minor. On two of the counts the court ordered Defendant to serve a five-year prison term, with each term to run consecutively to the other. On the third count, the court ordered Defendant to serve a five-year term of community control to be served consecutively to the prison terms imposed on the other two counts. The court of appeals affirmed the sentence. The Supreme Court reversed, holding that there was no statutory basis for ordering that a defendant be assessed for placement in a community-based correctional facility after that defendant's completion of a prison term imposed for another offense in that case. View "State v. Hitchcock" 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 habeas corpus against the warden of the Marion Correctional Institution, holding that Appellant's noncompliance with Ohio Rev. Code 2969.25(C) was a sufficient reason to dismiss the petition. The court of appeals dismissed the petition because Appellant, an inmate, had failed to submit an inmate-account statement, as required by section 2969.25(C), and because it was clear that Appellant was not entitled to immediate release. The Supreme Court affirmed, holding that the court of appeals correctly dismissed Appellant's petition for noncompliance with section 2969.25(C). View "State ex rel. Ellis v. Wainwright" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's action seeking a writ of mandamus to compel Judge Christine Croce to vacate his sentences, merge certain offenses, and resentence him, holding that Appellant could have raised his claims by appealing his sentence. Appellant pleaded guilty to aggravated burglary, felonious assault, rape and kidnapping. Finding that Appellant's offenses were separate and should not be merged at sentencing the trial court imposed a prison term for each offense and ordered the terms to be served consecutively. Appellant later filed his mandamus action. The court of appeals dismissed the complaint, determining that Appellant had an adequate remedy at law. The Supreme Court affirmed, holding that the court of appeals correctly determined that Appellant did not lack an adequate remedy in the ordinary course of the law because he could have raised his claims by appealing his sentence. View "State ex rel. Cowell v. Croce" on Justia Law

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The Supreme Court dismissed this original action in mandamus for failure to state a claim, holding that Relator was not entitled to mandamus relief. Relator, an inmate, brought this action against Respondents, nine public officials in Scioto and Franklin Counties, seeking to compel Respondents to investigate and prosecute his allegations of criminal activity and to issue arrest warrants based on the allegations. Respondents filed motions to dismiss, arguing that the complaint failed to comply with Ohio Rev. Code 2969.25's filing requirements. The Supreme Court denied the motions to dismiss because section 2969.25 did not apply. Under an independent assessment of the sufficiency of the mandamus complaint, the Court nonetheless dismissed the complaint, holding that the complaint failed to state a claim for relief in mandamus because Relator failed to allege facts that, if proved, would establish a clear legal duty to act on the part of Respondents. View "State ex rel. Evans v. Tieman" 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 habeas corpus, holding that the court of appeals correctly concluded that Appellant's petition failed to comply with the requirements of Ohio Rev. Code 2725.04(D). Appellant was imprisoned for various offenses. Appellant filed a petition for a writ of habeas corpus against the warden of the Marion Correctional Institution claiming that his maximum aggregate sentence had expired. The court of appeals granted the warden's motion to dismiss or for summary judgment, holding that Appellant had failed to attach relevant commitment papers and that his claims were barred by res judicata. View "Dailey v. Wainwright" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals vacating Defendant's convictions for violation of Defendant's right to a speedy trial, holding that speedy-trial time is tolled when a defendant's request for a continuance is made in open court and on the record or the reasons for the request are evidence from the record. The trial court denied Defendant's motion to dismiss the misdemeanor charges against her for violation of her right to a speedy trial, concluding that, after factoring in the periods of delay attributable to Defendant, ninety days had not elapsed from the date of her arrest to the date she filed her motion to dismiss. The court of appeals reversed and vacated Defendant's convictions, holding that the continuances in this case, while entered on behalf of Defendant, must be charged against the State because the trial court's journal entries either failed to identify Defendant as the requesting party or failed to explain the precise reasons for the delay. The Supreme Court reversed, holding that speedy-trial time is not chargeable to the State when the reasons for the defendant's request for a continuance are evident from the record, regardless of whether or not the trial court specifically journalizes those reasons on its docket sheet. View "State v. Martin" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals denying Appellant's Civ.R. 60(B) motion for relief from judgment and denied the five motions that Appellant filed in this case, holding that the court of appeals did not abuse its discretion in denying Appellant's motion. Appellant filed a complaint for a writ of mandamus arguing that he was entitled to be released from prison. The court of appeals dismissed the complaint, concluding that Appellant was not entitled to a writ of mandamus. Appellant then filed a Civ.R. 60(B) motion seeking relief from the court of appeals' judgment. The court of appeals denied the motion. Appellant later moved for relief from judgment on the same grounds previously asserted. The court of appeals denied the motion on res judicata grounds. The Supreme Court affirmed after denying the Ohio Department of Rehabilitation and Correction's motion to dismiss, holding (1) the court of appeals correctly denied Appellant's second Civ.R. 60(B) motion on the basis of res judicata; and (2) none of Appellant's pending motions had merit. View "State ex rel. Richard v. Chambers-Smith" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus and/or procedendo to compel Franklin County Court of Common Pleas Judge William H. Woods to issue a corrected sentencing entry, holding that Appellant had an adequate remedy in the ordinary course of the law by way of appeal. In 2006, the common pleas court issued an entry resentencing Defendant for his 2005 convictions for murder and felonious assault. In 2017, Defendant filed in the court of appeals a complaint for a writ of mandamus and/or procedendo arguing that he was entitled to a new sentencing entry that complied with Ohio Rev. Code 2505.02 and Crim.R. 32(C). The court of appeals dismissed the complaint for failure to state a claim. The Supreme Court affirmed, holding that Appellant's action was barred because he had an adequate remedy at law. View "State ex rel. White v. Woods" 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 Appellee, Judge Megan E. Shanahan of the Hamilton County Court of Common Pleas, to provide public records relating to his incarceration, holding that Appellant improperly sought records under the Public Records Act rather than the Rules of Superintendence. Appellant was convicted of aggravated burglary, abduction, and rape. Appellant later filed motions seeking the inspection and release of public records relating to his case. Judge Shanahan denied the motions, noting that Appellant could access all publicly available records through the clerk of courts. Appellant then filed his petition for a writ of mandamus. The court of appeals dismissed the writ, concluding that since Appellant was incarcerated, a sentencing court must first determine that the court records were necessary to support a justiciable claim. The Supreme Court affirmed but on different grounds, holding that the court of appeals erred in applying the Ohio Public Records Act, Ohio Rev. Code 149.43, to Appellant's records request and that the court of appeals correctly dismissed the case. View "State ex rel. Husband v. Shanahan" on Justia Law