Articles Posted in Supreme Court of Ohio

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The Supreme Court affirmed the judgment of the court of appeals dismissing the petition of Appellant for a writ of habeas corpus. In his petition, Appellant claimed that he had served the maximum sentence on his convictions and was entitled to immediate release from prison. The court of appeals dismissed Appellant’s petition for failing to comply with Ohio Rev. Code 2969.25(A) and (C). The Supreme Court held that the court of appeals correctly determined that Appellant failed to comply with section 2969.25(A) and thus properly dismissed the action. View "State ex rel. Perotti v. Clippper" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals dismissing the complaint of Appellant for writs of mandamus and/or procedendo against Summit County Court of Common Pleas Judge Christine Croce. In his complaint, Appellant argued that his sentence was void because the trial court incorrectly found that none of the offenses were allied offenses and it failed to make the necessary findings before imposing consecutive sentences. The court of appeals dismissed the complaint on the grounds that Appellant had failed to comply with the mandatory filing requirements of Ohio Rev. Code 2969.25(A) and (C). The Supreme Court held that the court of appeals correctly determined that Appellant failed to comply with section 2969.25(C) and thus properly dismissed the action. View "State ex rel. Cowell v. Croce" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals concluding that the exclusionary rule is not the appropriate remedy when police executing a valid search warrant violate the requirements of the knock-and-announce statute, Ohio Rev. Code 2935.12. The court of appeals reversed the judgment of the trial court granting Defendants’ motion to suppress all evidence obtained during the search of an apartment. The trial court found that police had violated section 2935.12 without any exigent circumstances justifying the violation. The Supreme Court agreed with the appellate court and remanded the cause to the trial court for further proceedings, holding that the exclusion of evidence is not the proper remedy for a violation of the knock-and-announce statute. View "State v. Bembry" on Justia Law

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The Supreme Court reversed Defendant’s conviction for aggravated murder and the death sentence imposed in connection with the aggravated murder, holding that the trial court committed plain error in admitting into evidence five knives that Defendant owned that were unrelated to his crimes of felony aggravated murder and other felonies at issue on appeal. The court concluded that the evidence at issue painted Defendant as someone with bad character and allowed the jury to convict him on the basis that he acted in conformity with it, thus violating Ohio R. Evid. 404(B). The court remanded the case for a new trial. View "State v. Thomas" on Justia Law

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Pursuant to Ohio Rev. Code 2953.52(B)(4), a trial court may seal the records in a case dismissed without prejudice before the statute of limitations has expired. Here, the State filed a complaint against Defendant charging him with arson, among other crimes. The State later dismissed the complaint without prejudice. Defendant filed an application to seal the official records of the case pursuant to section 2953.52. The trial court denied the application on the grounds that the case had been dismissed without prejudice and the statute of limitations had not yet expired. The court of appeals affirmed. The Supreme Court reversed, holding that section 2953.52 does not require the relevant statute of limitations to expire before a trial court can grant an application to seal the records of a case dismissed without prejudice. View "State v. Dye" on Justia Law

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In this original action, Relator sought a writ of prohibition to bar the Twelfth District Court of Appeals from hearing the State’s appeal of the trial court’s judgment of acquittal under Ohio R. Crim. P. 29(A). The appellate court filed a motion to dismiss, and Relator asked for leave to amend his complaint. The Supreme Court granted Relator’s motion for leave to amend, denied the appellate court’s motion to dismiss, and granted a peremptory writ of prohibition barring the Court of Appeals from hearing the State’s appeal, holding that the Twelfth District failed to show that it had jurisdiction to hear the State’s appeal. View "State ex rel. Ramirez-Ortiz v. Twelfth District Court of Appeals" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals denying Petitioner’s petition for a writ of mandamus, holding that the claims asserted in the petition were barred by res judicata. Petitioner pleaded guilty, pursuant to a plea agreement, to two counts of aggravated murder. Instead of appealing, Petitioner filed a petition for a writ of mandamus, arguing that the sentencing entry was void and that he was entitled to a new sentencing hearing. The issues for review presented in the mandamus petition were identical to the claims asserted in Petitioner’s motion before the trial court. The court of appeals denied the mandamus petition. The Supreme Court affirmed, holding that the claims asserted in the petition were barred by res judicata. View "State ex rel. Hughes v. Cuyahoga County" on Justia Law

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In this original action, Relator requested a writ of prohibition to void the court of appeals’ judgment in the State’s appeal of a judgment granting Relator postconviction relief, to void the common pleas judge’s subsequent orders on remand, and to preclude the court of appeals from ruling on Relator’s direct appeal of the judge’s denial of his motion for a new trial. Upon the State’s appeal, the court of appeals reversed the court of common pleas’ determination that Relator, who was convicted of murdering his former wife, was actually innocent of the aggravated murder and grant of postconviction relief under Ohio Rev. Code 2953.21. On remand, a new common pleas judge reinstated Relator’s aggravated murder conviction and sentence. The Supreme Court denied the writ of prohibition, holding (1) Ohio Rev. Code 2945.67(A) and 2953.23(B) unambiguously allow the State an absolute right to appeal a judgment granting postconviction relief; and (2) therefore, Respondents’ exercise of jurisdiction following the trial court’s judgment was not unauthorized by law. View "State ex rel. Prade v. Ninth District Court of Appeals" on Justia Law

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The Supreme Court affirmed Defendant’s convictions of aggravated murder with three death specifications and his sentence of death. The court held (1) the trial court did not err by denying Defendant’s motion for change of venue; (2) Defendant’s trial counsel did not render ineffective assistance in conducting voir dire; (3) the trial court did not err by denying Defendant’s motion to suppress the murder weapon as evidence; (4) the trial court did not err in refusing to suppress Defendant’s post-arrest statements; (5) the evidence was legally sufficient to convict Defendant of tampering with evidence; (6) guilt-phase evidence was properly used against Defendant in the penalty phase; (7) the state did not make improper statements during closing arguments in the penalty phase; (8) there was no error in the trial court’s sentencing opinion; and (9) the death sentence was proportionate to those affirmed in similar cases. View "State v. Martin" on Justia Law

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At issue in this case was whether the law-of-the-case doctrine requires a court to apply the findings of a superior court in a criminal case to a civil case brought by the criminal defendant against individuals and entities who were not parties to the criminal case. The court held that the law-of-the-case doctrine does not require a court to follow a superior court’s decision in a prior appeal involving one of the parties but in the context of a different case. Rather, the law-of-the-case doctrine applies only to rulings in the same case. The Supreme Court reversed the judgment of the court of appeals, which ruled that summary judgment was improper in this case because the law-of-the-case doctrine applied. The Supreme Court held that the appellate court’s holding was not a proper application of the law-of-the-case doctrine. View "Reid v. Cleveland Police Department" on Justia Law