Justia Criminal Law Opinion Summaries

Michael Jones was convicted by a jury of ten drug-trafficking and drug-possession charges. Before the trial, Jones filed a motion to suppress evidence seized from a safe in a house, arguing that the consent to search was invalid and the search warrant for the safe was insufficient. The trial court denied the motion and sentenced Jones to an aggregate prison term of 22 to 24.5 years.Jones appealed to the First District Court of Appeals, arguing ineffective assistance of counsel for not challenging the evidence as coerced and the protective sweep as unconstitutional. The appellate court agreed, finding that Jones's trial counsel had a reasonable basis to challenge the consent and the protective sweep. The court concluded that the failure to raise these arguments constituted deficient performance and prejudiced Jones. The appellate court ordered a limited remand for Jones to file a new motion to suppress and for the trial court to hold a suppression hearing, staying the consideration of Jones’s remaining assignments of error.The Supreme Court of Ohio reviewed the case and determined that it had jurisdiction under Article IV, Section 2(B)(2) of the Ohio Constitution and R.C. 2505.03(A). The court found that the First District did not comply with App.R. 12(A)(1)(a) and (c) because it did not affirm, modify, or reverse the trial court’s judgment and did not decide all assignments of error. The Supreme Court reversed the judgment of the First District, vacated its entry ordering limited remand, and remanded the case to the First District to enter a judgment that complies with App.R. 12. View "State v. Jones" on Justia Law

An inmate at the Marion Correctional Institution, Willard McCarley, submitted a statement alleging sexual assault by a prison doctor. The institutional investigator found the allegation to be false and issued a conduct report accusing McCarley of violating Rule 27, which prohibits giving false information to departmental employees. The Rules Infraction Board (RIB) found McCarley guilty and placed him in disciplinary control for 14 days. McCarley appealed the decision to the warden and the Ohio Department of Rehabilitation and Correction’s (DRC) chief legal counsel, both of whom affirmed the RIB’s decision.McCarley then filed a mandamus action in the Tenth District Court of Appeals, seeking to compel the DRC to vacate the RIB’s decision. He argued that there was no evidence to support the finding that he lied. The court referred the matter to a magistrate, who recommended granting the DRC’s motion for judgment on the pleadings, stating that McCarley failed to show a clear legal right to the relief sought or a clear legal duty on the part of the DRC. The court of appeals initially remanded the case to the magistrate to address the sufficiency of evidence but ultimately adopted the magistrate’s recommendation and denied the writ.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District’s judgment. The court held that McCarley did not demonstrate that the RIB’s guilty finding imposed an atypical and significant hardship or affected the duration of his confinement, which are necessary to establish a constitutionally protected liberty interest. Additionally, the court found that the RIB’s decision was supported by “some evidence,” specifically the “unfounded” finding of the PREA investigation. Therefore, McCarley was not entitled to mandamus relief, and the DRC was entitled to judgment as a matter of law. View "State ex rel. McCarley v. Dept. of Rehab. & Corr." on Justia Law

Damien L. Peterson was convicted of multiple felonies in November 2019, stemming from four armed robberies in Cleveland. He was arrested by Shaker Heights Police in April 2019 and charged with aggravated robbery. His case was transferred to the Cuyahoga County Court of Common Pleas, where he was convicted and sentenced to 39 to 41.5 years in prison. In May 2023, Peterson petitioned the Eighth District Court of Appeals for a writ of prohibition against Judge Sherrie Miday, alleging that she lacked jurisdiction over his case due to procedural errors, including the absence of a preliminary hearing and bindover order from the municipal court.The Eighth District Court of Appeals dismissed Peterson's petition, citing res judicata, as his claims had been previously raised and found meritless. The court also denied his motion for judgment on the pleadings and declared him a vexatious litigator under its local rules due to his repetitive and baseless filings.The Supreme Court of Ohio reviewed the case and affirmed the Eighth District's judgment but for different reasons. The Supreme Court found that Judge Miday did not patently and unambiguously lack jurisdiction over Peterson's criminal case, as the Cuyahoga County Court of Common Pleas has general jurisdiction over felony cases. The procedural issues Peterson raised, such as the lack of a preliminary hearing and bindover order, did not divest the court of its jurisdiction. Additionally, Peterson had adequate remedies in the ordinary course of the law, such as appeals, to address his claims.The Supreme Court also upheld the Eighth District's decision to declare Peterson a vexatious litigator, noting that his repeated filings of the same arguments constituted frivolous conduct. The court concluded that the Eighth District did not abuse its discretion in making this determination. View "State ex rel. Peterson v. Miday" on Justia Law

Marc D. Curtis, an inmate at the North Central Correctional Complex, requested records from the Cleveland Municipal Court Clerk, Earle B. Turner, related to his criminal case. Curtis sought documents including arrest warrants, DNA search warrants, and cellphone search warrants. The clerk provided some documents but withheld others, citing that Curtis, as an inmate, could not access certain records without a judge's approval per R.C. 149.43(B)(8). Curtis filed a mandamus complaint to compel the clerk to produce the remaining records or confirm their nonexistence.The Eighth District Court of Appeals denied Curtis's writ of mandamus. The court relied on an affidavit from Ronald Tabor, the clerk’s assistant director, who stated that the clerk did not possess the requested records. The court found this affidavit sufficient to establish that the records were not in the clerk’s possession and noted that respondents are not required to create or provide access to nonexistent records.The Supreme Court of Ohio reviewed the case and affirmed the Eighth District's judgment. The court held that Curtis failed to provide clear and convincing evidence that the clerk possessed the requested records. The court also denied Curtis's motion to take judicial notice of new documents and granted the clerk's motion to strike certain personal information from the record. The court concluded that the clerk had adequately demonstrated that the requested records were not in his possession, and Curtis did not rebut this evidence. View "State ex rel. Curtis v. Turner" on Justia Law

Elvin Maldonado was convicted in 2019 of multiple counts of felonious assault and discharging a firearm, with accompanying firearm specifications, and was sentenced to nine years in prison and ordered to register as a violent offender. Maldonado successfully appealed, and the Eighth District Court of Appeals remanded the case to the trial court to vacate the firearm specification sentence and the violent offender registration requirement. On remand, the trial court refused to hold a hearing and issued a new sentencing entry as directed.Maldonado appealed again, arguing that he was entitled to a hearing and that the trial court failed to properly calculate his jail-time credit. The Eighth District Court of Appeals identified a conflict between two of its prior decisions on whether a defendant is entitled to a hearing when part of a sentence is vacated. Before the panel issued its decision, the court decided to resolve the conflict en banc. The en banc court held that a defendant does not have a right to a resentencing hearing in such circumstances, and the panel affirmed the trial court’s judgment based on this en banc decision.The Supreme Court of Ohio reviewed the case and agreed that the Eighth District violated App.R. 26(A)(2) by conducting en banc review before the panel decision was released. However, the Supreme Court found that Maldonado was not prejudiced by this procedural error. The court noted that even if a hearing had been held, Maldonado’s sentence would not have changed, as the remand was only to vacate specific parts of the sentence without altering the overall sentence. Consequently, the Supreme Court of Ohio affirmed the judgment of the Eighth District Court of Appeals. View "State v. Maldonado" on Justia Law

Andre M. Yeager, an inmate at the Richland Correctional Institution, represented himself in a trial where he was found guilty of grand theft, breaking and entering, and vandalism. He was sentenced to an aggregate prison term of 39 months. Yeager appealed his convictions to the Eleventh District, arguing that the trial court erred by allowing him to represent himself. The Eleventh District affirmed the trial court’s judgment of conviction.Yeager then filed an action in the Eleventh District, seeking a writ of prohibition to prevent the trial court from enforcing his convictions and a writ of mandamus directing the trial court to vacate his convictions. He claimed that his case was improperly assigned to the trial-court judge, the trial court violated his right to counsel, and the prosecution withheld exculpatory evidence. The Eleventh District dismissed Yeager’s complaint for failure to state a claim upon which relief can be granted.The Supreme Court of Ohio affirmed the Eleventh District Court of Appeals’ judgment. The court found that Yeager had an adequate remedy in the ordinary course of the law to raise his claims, as he had already exercised that remedy by filing a direct appeal from the trial court’s judgment of conviction. The court also found that the trial court did not patently and unambiguously lack jurisdiction. Therefore, Yeager was not entitled to a writ of prohibition precluding the trial court from enforcing his convictions or a writ of mandamus vacating his convictions. View "State ex rel. Yeager v. Lake Cty. Court of Common Pleas" on Justia Law

The case revolves around James E. Mitchell, an inmate serving a 160-year prison sentence for a 1994 conviction in Summit County, which is to be served consecutively to a 3- to 15-year prison sentence imposed for a June 1994 conviction in Portage County. Mitchell filed a petition for a writ of habeas corpus against Warden George A. Fredrick and the Ohio Adult Parole Board, arguing that the Portage County trial court lacked jurisdiction when it sentenced him on his guilty plea to burglary and gross sexual imposition. He claimed that no judgment of conviction and sentence had been imposed on him regarding the indicted offenses of rape and aggravated burglary, rendering his prison sentence void.Mitchell's petition was initially reviewed by the Third District Court of Appeals, which dismissed his petition. The court concluded that Mitchell failed to raise a claim cognizable in habeas corpus and failed to show that his prison sentence had expired. It also noted that Mitchell had adequate remedies in the ordinary course of the law to raise his claims.The case was then reviewed by the Supreme Court of Ohio. The court affirmed the judgment of the Third District Court of Appeals, dismissing Mitchell's petition for a writ of habeas corpus. The Supreme Court found that the Portage County trial court had subject-matter jurisdiction to accept Mitchell’s guilty plea to burglary and gross sexual imposition and to sentence him accordingly. Any defects in the trial court’s sentencing entry were deemed to implicate the trial court’s exercise of jurisdiction over Mitchell’s criminal case, not the court’s subject-matter jurisdiction. The court also noted that Mitchell had adequate remedies, which he pursued. Therefore, the court concluded that the dismissal of Mitchell's petition was correct based on adequate-remedy grounds. View "State ex rel. Mitchell v. Fredrick" on Justia Law

The case involves Damon L. Taylor, who was charged with felony murder in the adult court after the juvenile court found probable cause to believe that Taylor was complicit in a murder. The adult court convicted Taylor of felony murder, but the Tenth District Court of Appeals vacated the conviction, arguing that the adult court lacked jurisdiction to convict Taylor of felony murder as the juvenile court had not found probable cause for that specific offense. The appellate court also ruled that Taylor's statements to the police should have been suppressed as his Sixth Amendment right to counsel had been violated.The Supreme Court of Ohio disagreed with the appellate court's decision. The Supreme Court held that the adult court did have jurisdiction over the felony-murder charge against Taylor. The court reasoned that the felony-murder charge was rooted in the same acts and events as the complicity-to-commit-murder charge, which was the subject of the juvenile complaint. Therefore, under former R.C. 2151.23(H), the adult court had jurisdiction over the felony-murder charge.Regarding Taylor's Sixth Amendment right to counsel, the Supreme Court held that this right did not attach until a criminal prosecution had commenced, which occurred after the police interrogated Taylor. Therefore, the state did not violate Taylor's Sixth Amendment right to counsel when it interviewed him in the absence of his attorney. Even if the Sixth Amendment right to counsel had attached, Taylor validly waived it when he relinquished his Fifth Amendment right to counsel after he received the Miranda warnings.The Supreme Court reversed the judgment of the Tenth District Court of Appeals and remanded the matter to that court for further proceedings. View "State v. Taylor" on Justia Law

The case revolves around Fadi Salem, who was convicted of third-degree-misdemeanor sexual imposition in February 2021. As per Ohio law, this conviction classified him as a Tier I sex offender, requiring him to register and report to the sheriff. However, the judgment entry of conviction did not explicitly state this classification. Salem later filed a motion to terminate his Tier I sex-offender classification and registration requirements, arguing that the initial judgment did not impose this classification. The trial court denied this motion and issued a nunc pro tunc judgment entry designating Salem a Tier I sex offender.Salem appealed the trial court's denial of his motion to the Twelfth District Court of Appeals. The court of appeals upheld the trial court's decision, stating that the trial court had provided Salem with the required notice of his Tier I sex-offender classification and registration requirements during the sentencing hearing. The court also held that the trial court was permitted to issue a nunc pro tunc judgment entry reflecting the imposition of the Tier I classification.While his appeal was pending, Salem filed a complaint for a writ of mandamus in the court of appeals, asking for a writ compelling the sheriff to enforce the initial judgment without the Tier I sanction. The court of appeals dismissed this complaint, stating that Salem's appeal was an adequate remedy that precluded relief in mandamus.The Supreme Court of Ohio affirmed the judgment of the Twelfth District Court of Appeals. The court held that Salem's appeal from the trial court's judgment denying his motion to terminate his Tier I sex-offender classification and registration requirements was an adequate remedy. The court also noted that the fact that Salem's appeal was unsuccessful did not render that remedy inadequate. View "State ex rel. Salem v. Jones" on Justia Law

The case revolves around Deonta Boyd, an inmate at the Richland Correctional Institution, who pleaded guilty in 2006 to aggravated murder with a firearm specification, felonious assault, and aggravated burglary. The trial court accepted Boyd's pleas and sentenced him to life imprisonment with parole eligibility after 41 years. Boyd did not appeal his convictions or sentence but has attempted unsuccessfully to withdraw his guilty pleas multiple times. In March 2023, Boyd filed a complaint for a writ of prohibition, claiming that the trial court violated his rights under the Fifth, Sixth, and Fourteenth Amendments to the United States Constitution and their counterparts in the Ohio Constitution. He alleged that the trial court failed to inform him that he was waiving his constitutional right to compulsory process at the 2006 plea hearing.The Sixth District Court of Appeals dismissed Boyd's prohibition complaint, holding that Boyd could have challenged any defect in the plea colloquy on direct appeal and that any issue concerning the trial court’s alleged failure to advise him of his right to compulsory process is therefore barred by res judicata. Boyd appealed the dismissal of his complaint.The Supreme Court of Ohio affirmed the Sixth District Court of Appeals' judgment. The court found that Boyd had adequate remedies in the ordinary course of the law to raise his claim, including a direct appeal, a petition for postconviction relief, and a motion to withdraw his guilty pleas. The court also found that the trial court did not patently and unambiguously lack subject-matter jurisdiction to convict him. Therefore, Boyd was not entitled to a writ of prohibition, and the Sixth District correctly dismissed the prohibition action. View "State ex rel. Boyd v. Tone" on Justia Law