Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's complaint for a writ of habeas corpus against the warden of the Madison Correctional Institution, holding that the court of appeals correctly denied Appellant's petition for a writ of habeas corpus.Appellant was convicted of rape, felonious sexual penetration, and gross sexual imposition. Appellant later filed the complaint for a writ of habeas corpus at issue in this case, alleging that the trial court had sentenced him for an offense when it lacked jurisdiction to do so and, alternatively, that the trial court failed to impose a judgment that satisfied the requirements of Crim.R. 32. The court of appeals denied the writ. The Supreme Court affirmed and denied Appellant's motion for transcripts and journal entires, holding that Appellant's propositions of law were either waived or that Appellant's remedy did not lie in habeas corpus. View "State ex rel. Haddix v. Warden" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus seeking release from custody on bail on reasonable conditions of bond, holding that habeas corpus was not the proper action by which to challenge the trial court's denial of bail.Appellant, who was being held without bail pending trial for rape and other charges, filed a verified complaint seeking a writ of habeas corpus ordering the Franklin County Sheriff Dallas Baldwin to release him from custody and "let him to bail" upon reasonable conditions of bond. The court of appeals granted the sheriff's motion to dismiss. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law by means of appeal from the denial of his requests for pretrial release on bail, thus excluding extraordinary relief in habeas corpus. View "State ex rel. Garcia v. Baldwin" on Justia Law

The Supreme Court denied Relator's complaint seeking a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction (DRC) to provide documents in response to submitted public records requests, holding that this action was moot.Relator, an inmate at the London Correctional Institution, sent several requests to the DRC for records and kites. DRC provided a requested record and concluded that the remaining records were electronic kites. Relator then made subsequent requests. The DRC denied the requests and ultimately gave Relator a formal directive to stop the repetitive requests. Relator then filed his mandamus complaint. The Supreme Court denied the writ and awarded Relator $1,000 in statutory damages, holding (1) Relator's requests for the kites were moot because the DRC provided all the requested kites; and (2) Relator was entitled to statutory damages. View "State ex rel. Straughter v. Ohio Dep't of Rehabilitation & Correction" on Justia Law

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 Trumbell Correctional Institution, where Appellant was serving a forty-year prison sentence, holding that there was no error.Appellant was serving his prison sentence for nine convictions for felonious assault, in violation of Ohio Rev. Code 2903.11(B)(3). Appellant filed a petition for a writ of habeas corpus arguing, inter alia, that section 2903.11(B)(3) violates the Equal Protection Clauses of the Ohio and United States Constitution. The court of appeals dismissed the petition for failure to state a valid claim for habeas relief. The Supreme Court affirmed, holding that habeas corpus did not lie for Appellant's nonjurisdictional claims. View "Christian v. Davis" on Justia Law

The Supreme Court remanded this case to the trial court for it to enter a judgment of conviction against Appellant for criminal trespass under Ohio Rev. Code 2911.21(A)(1) and to sentence him in accordance with this opinion, holding that insufficient evidence supported Appellant's conviction of burglary.Under Ohio Rev. Code 2911.12(A)(2), the State was required to prove that Appellant trespassed by "force, stealth, or deception" in order to convict him of burglary. The court of appeals affirmed the conviction. The Supreme Court reversed and vacated Appellant's burglary conviction and judicial sanction, holding (1) to prove a defendant trespassed by stealth or deception in a burglary case the State must prove that the defendant actively avoided discovery or used deceptive conduct to gain entry to the structure; and (2) the evidence in this case was insufficient to convict Appellant of burglary but sufficient to convict him of criminal trespass. View "State v. Bertram" on Justia Law

The Supreme Court granted in part and denied a writ of mandamus sought by Relator compelling the clerk of the Circleville Municipal Court, Charma Cantrell, to comply fully with a public-records request Relator sent Cantrell under the Public Records Act, Ohio Rev. Code 149.43(B), holding that Relator was entitled to the writ in part.Relator, an inmate, brought this action demanding a writ of mandamus ordering Cantrell either to produce all records responsive to his January 2022 records request or explain why such records would not be produced. The Supreme Court granted the writ in part, holding (1) Relator was entitled to a writ of mandamus on his request to strike the evidence attached to Cantrell's merit brief because it was untimely submitted; and (2) Relator was not entitled to relief on his remaining arguments. View "State ex rel. Adkins v. Cantrell" on Justia Law

The Supreme Court granted in part and denied in part the Lawrence County Sheriff's Office's motion for judgment on the pleadings as to this action brought by Relator, an inmate, and denied as moot Relator's claim for a writ of mandamus, holding that the mandamus claim was moot.Relator sought certain records from the Lawrence County Sheriff's Office, which determined that the request was too vague to grant. Relator then filed this action requesting, among other things, a writ of mandamus ordering the Sheriff to produce the requested records and seeking awards of statutory damages, attorney fees, and court costs. The Sheriff filed a motion for judgment on the pleadings. Thereafter, Relator received the requested records. The Supreme Court held (1) the Sheriff was entitled to judgment on the pleadings as to Relator's mandamus claim, which was moot; (2) Relator was entitled to $700 in statutory damages but was not entitled to attorney fees and court costs; and (3) Relator's remaining motions were moot. View "State ex rel. Woods v. Lawrence County Sheriff's Office" on Justia Law

The Supreme Court dismissed this appeal of the decision of the court of appeals setting Appellant's bail at $250,000, holding that this appeal was moot.Appellant was indicted on several charges and arrested, and the trial court set bail at $500,000. The court of appeals granted Appellant's petition for a writ of habeas corpus on the grounds that his bail was unconstitutionally excessive and reduced his bail to $250,000. After Appellant appealed, he pleaded guilty and was sentenced. The Supreme Court dismissed the appeal from the bail order, holding that Appellant's appeal was moot, and Appellant had not shown that a mootness exception applied in this case. View "State ex rel. Casanova v. Lutz" on Justia Law

The Supreme Court granted a writ compelling the Mansfield Correctional Institution to produce records requested by Relator against the Mansfield Correctional Institution under Ohio's Public Records Act, Ohio Rev. Code 149.43, holding that Relator was entitled to a writ.Relator requested information and records from the prison warden's office regarding three assaults committed against her son while he was incarcerated at the prison. After the prison asserted that all responsive records had been produced Relator brought this action. The Supreme Court granted the writ with respect to some of the requested records and granted a limited writ compelling the prison to produce additional requested records or to certify that no responsive records existed and denied Relator's motions to transfer this case to the court of claims, to strike the prison's merit brief, and other motions, holding (1) the prison failed to prove that certain withheld information fell squarely within an exception to the Act; (2) the prison did not carry its burden of proving that no other documents existed that were responsive to certain requests; and (3) Relator was not entitled to a writ of mandamus as to the remaining evidence. View "State ex rel. Sultaana v. Mansfield Correctional Institution" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a petition for a writ of habeas corpus sought by Appellant, holding that the court of appeals properly weighed the evidence.Appellant, Pele Bradford, filed a petition for a writ of habeas corpus alleging that his convictions for aggravated murder and other offenses were void because he was seventeen years old at the time of the offenses and not bound over from juvenile court. The Supreme Court reversed the court of appeals' decision granting summary judgment in favor of the warden because the court of appeals improperly considered a copy of a birth certificate attached to the warden's motion for summary judgment. On remand, the court of appeals denied the writ. On appeal, Appellant argued that the court of appeals "improperly consider[ed] the warden's return of the writ" and that a certain filing by the warden should have been stricken. The Supreme Court affirmed, holding that the court of appeals properly weighed the evidence after treating the warden's filing as a return of writ. View "State ex rel. Bradford v. Bowen" on Justia Law