Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus against the warden of the Pickaway Correctional Institution (PCI), where Appellant was an inmate, and denied Appellant's motion to supplement his merit brief with additional documents, holding that Appellant was not entitled to relief.According to Appellant, he was indicted in Franklin County for a crime that was committed in Fairfield County. Appellant filed a petition for a writ of habeas corpus asserting that Franklin County lacked venue or subject-matter jurisdiction. The court of appeals denied relief. The Supreme Court affirmed, holding that Appellant's petition failed to state a claim that is cognizable in habeas corpus. View "State ex rel. Norman v. Collins" on Justia Law

The Supreme Court granted a peremptory writ of prohibition compelling the probate-juvenile court to vacate its order granting the applications for immunity filed by two witnesses in a criminal case under Ohio Rev. Code 2945.44, holding that the probate-juvenile court patently and unambiguously lacked jurisdiction to grant the applications.Relator was charged with misdemeanor counts relating to her juvenile son, L.C. The prosecution filed an application in the county court seeking immunity for L.C. under section 2945.44, but the judge denied the application for want of jurisdiction. Thereafter, the prosecution filed an application in the probate-juvenile court requesting immunity for both L.C. and his stepbrother, M.R. The judge granted immunity to both witnesses. Relator then sought a writ of mandamus to compel the judge to vacate his order and a writ of prohibition. The Supreme Court granted a writ of prohibition in part and denied it in part and denied a writ of mandamus, holding the probate-juvenile court patently and unambiguously lacked jurisdiction to grant immunity under section 2945.44. View "State ex rel. Simpson v. Kirby" on Justia Law

The Supreme Court granted in part and denied in part this action seeking a writ of mandamus ordering Hamilton County Clerk of Courts Pavan Parikh to provide copies of three oaths of office and various court records from a 2001 case and awards of statutory damages and costs, holding that Relator was entitled to mandamus in part.Relator, an inmate, sent a public records request requesting three judges' oaths of office and documents from a case filed in 2001. When the clerk of courts did not respond to the public-records request Relator filed this action. The Supreme Court granted relief in part, holding (1) Relator used the incorrect vehicle for requesting copies of the oaths of office; and (2) the clerk did not meet his burden to show that Ohio Rev. Code 149.43(B)(8) foreclosed Relator's right to receive the second portion of his records request. View "State ex rel. Ware v. Parikh" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's original action captioned “Petition for discharge for want of jurisdiction, judicial misconduct, and abuse of discretion, obstructions to justice, prosecutorial misconduct & perjury, & Brady rule violations, etc., effected pre-trial by respondents,” holding that the court of appeals did not err.In her complaint, which the court of appeals justice designated as an "appeal" from an earlier criminal judgment, Appellant argued that her speedy-trial rights had been violated, that the prosecution had withheld exculpatory evidence, and that the trial court had abused its discretion in various pretrial rulings. The court of appeals dismissed the complaint, concluding that it was insufficient to state a claim. The Supreme Court affirmed, holding that the court of appeals correctly dismissed the complaint for failure to state a claim within the jurisdiction of the court of appeals. View "State ex rel. Justice v. State" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's petition for a writ of habeas corpus against the warden of the North Central Correctional Complex, holding that the court of appeals correctly dismissed Appellant's petition for failure to state a claim upon which relief in habeas corpus could be granted.Appellant pled no contest to gross sexual imposition, pandering sexually-oriented material involving a minor, and illegal use of a minor in nudity-oriented material. Appellant later filed a petition for a writ of habeas corpus, alleging that the trial court lacked jurisdiction to try him. The court of appeals dismissed the petition for failure to state a claim. The Supreme Court affirmed, holding that Appellant was not entitled to relief on his propositions of law. View "State ex rel. Martre v. Watson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Michael Bell's petition seeking a writ of habeas against the warden of the Mansfield Correctional Institution (MCI) and denied Bell's motion to reverse and vacate the judgment against him, holding that Bell was not entitled to relief.Bell, an inmate at MCI, filed a petition for a writ of habeas corpus against MCI's warden, presenting several arguments to support his claim for relief. The court of appeals granted the warden's motion to dismiss for failure to state a valid claim for relief in habeas corpus. The Supreme Court affirmed, holding that Bell could not establish that he was entitled to habeas relief under any of the theories he presented. View "Bell v. McConahay" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that Appellant was not entitled to relief on his propositions of law.Appellant was convicted of rape of a minor and other crimes. Appellant later brought this petition for a writ of habeas corpus alleging that after serving his mandatory minimum sentence he satisfied the conditions for parole and had been granted release and that he had a right to immediate release. The court of appeals denied the petition. The Supreme Court affirmed, holding that the error of the Ohio Department of Rehabilitation and Correction misinforming Appellant about his parole status did not create a constitutional right to parole. View "State ex rel. Lindsay v. Dep't of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of prohibition and mandamus seeking vacated of his criminal convictions, holding that Appellant had an adequate remedy in the ordinary course of the law.In 2009, Appellant was convicted of aggravated robbery and complicity to commit murder and sentenced to an aggregate term of twenty-eight years to life in prison. In 2022, Appellant filed his complaint for writs of prohibition and mandamus, arguing that the trial court lacked jurisdiction to "misapply" Ohio's aggravated robbery statute, Ohio Rev. Code 2911.01, requiring vacatur of his conviction. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law. View "State ex rel. Boler v. McCarthy" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that Appellant's Ohio Rev. Code 2969.25(A) affidavit was deficient, making his habeas corpus petition subject to dismissal.Appellant, an inmate at Trumbull Correctional Institution, filed a petition for a writ of habeas corpus against the warden, arguing that his underlying burglary conviction was void and that he was entitled to immediate release. The court of appeals granted the warden's motion to dismiss. The Supreme Court affirmed, holding that the court of appeals properly found that Appellant's affidavit did not strictly comply with the statute and in thus dismissing the petition. View "Westerfield v. Bracy" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus against warden of the Mansfield Correctional Institution, holding that the petition was properly dismissed.Since he was convicted in 1979 for numerous felony offenses Appellant had been released on parole and convicted of new crimes at least four times. In 2022, Appellant filed his petition for a writ of habeas corpus, arguing that his 1979 convictions were void. The court of appeals sua sponte dismissed the complaint on procedural grounds. The Supreme Court affirmed, holding that the court of appeals correctly dismissed the petition because Appellant did not comply with the mandatory filing requirements of Ohio Rev. Code 2725.04 and Ohio Rev. Code 2969.25. View "Robinson v. McConahay" on Justia Law