Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus and/or procedendo against the trial court, holding that Appellant's complaint failed to state a claim for relief in mandamus or procedendo and was properly dismissed.Appellant was found guilty of felony murder and aggravated vehicular homicide and sentenced to an aggregate prison term of twenty years. Appellant later filed a complaint seeking a writ of mandamus and/or procedendo compelling the trial court to enter judgment on each offense for which there was a conviction, namely, felonious assault. The court of appeals dismissed the complaint on the ground that Appellant had not been indicted on a separate charge of felonious assault. The Supreme Court affirmed, holding that the trial court was under no duty to dispose of a felonious assault charge in Defendant's criminal case because no such charge was brought against him. View "State ex rel. Myles v. Goering" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's mandamus action and denied Appellant's motions for default judgment and summary judgment, holding that the court of appeals properly dismissed the complaint.Appellant, a defendant in a criminal case, filed a complaint for a writ of mandamus seeking a writ compelling Hamilton County Court of Common Pleas Judge Robert Ruehlman to honor his motion to dismiss and to vacate the judgment below. The court of appeals granted Judge Ruehlman's motion to dismiss. The Supreme Court affirmed, holding that Appellant failed to state a valid claim for mandamus relief. View "Furr v. Ruehlman" on Justia Law

The Supreme Court granted a writ of mandamus sought by Matthew Lusane against the city of Kent police department, holding that Lusane was entitled both to the writ and to $1,000 in statutory damages.In 2022, Lusane delivered a public records request to the police department seeking all officer body cameras and cruiser dash camera video related to a certain incident. The department denied the request, stating that the videos fell under the public records disclosure exception for confidential law enforcement investigatory records. Lusane then filed this action requesting a writ of mandamus and seeking an award of statutory damages. The Supreme Court granted both the writ and awarded statutory damages, holding (1) the department improperly denied Lusane a copy of the videos; and (2) Lusane was entitled to $1,000 in statutory damages. View "State ex rel. Lusane v. Kent Police Dep't" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's third motion for relief from judgment filed after the court of appeals dismissed Appellant's complaint for a writ of mandamus, holding that the court of appeals correctly denied the motion.Appellant, who was serving sentences for aggravated murder and other crimes, filed an original action in the court of appeals seeking a writ of mandamus. The court of appeals dismissed the complaint and denied the writ. Appellant did not appeal the dismissal of his complaint but instead filed three motions for relief from judgment under Civ. R. 60(B), which the court of appeals denied. Appellant appealed from the court of appeals' denial of his third motion. The Supreme Court affirmed, holding that Appellant should have raised his claims of error in a timely appeal from the court of appeals' motion, not in a Civ.R. 60(B) motion. View "State ex rel. Hatfield v. French" 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 North Central Correctional Complex, where Appellant was an inmate, holding that the court of appeals properly denied Appellant relief in habeas corpus.In his petition for a writ of habeas corpus, Appellant sought immediate release from prison, arguing that he was unlawfully detained because he had fully served his sentences. The court of appeals granted summary judgment in favor of the warden. The Supreme Court affirmed, holding that the court of appeals correctly found that Appellant's maximum sentence had not expired. View "State ex rel. Jackson v. Watson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that the court of appeals correctly dismissed Appellant's petition.Appellant, an inmate at the Trumbull Correctional Institution, filed this petition for a writ of habeas corpus in 2021 seeking his immediate release from prison and alleging that he had completed his original sentence in 2020 and was being wrongfully imprisoned for his 1998 conviction. The court of appeals dismissed the petition because, among other things, Appellant's petition did not comply with Ohio Rev. Code 2969.25(A). The Supreme Court affirmed, holding that Appellant's failure to comply with section 2969.25(A) warranted dismissal. View "Alston v. Bracy" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court rejecting Defendant's amended petition for postconviction relief without holding a hearing, holding that the trial court erred in failing to hold an evidentiary hearing before reaching its decision.Defendant was convicted of rape, kidnapping, and other offenses. In his amended petition for postconviction relief Defendant asserted that his trial counsel had been ineffective for failing to present expert testimony to assist the jury in understanding the unreliability of eyewitness identification, particularly under the circumstances of this case. The trial court denied relief without holding a hearing. The Supreme Court reversed and remanded the case, holding that Defendant's ineffective assistance claim presented an issue that the trial court needed to examine at an evidentiary hearing before ruling on the claim. View "State v. Bunch" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the order of the trial court granting restitution to the victims of Defendant's theft, holding that, although the victims should be compensated for the loss of their stolen vehicle, they did not act to protect their right to restitution when they did not appeal the portion of Defendant's sentence denying restitution.Defendant pleaded guilty to grand theft of the victims' motor vehicle. The trial court sentenced Defendant to eighteen months in prison. Five months later, the victims filed a complaint for a writ of mandamus seeking an order to compel the trial court to hold a restitution hearing. The court of appeals granted summary judgment in favor of the victims and ordered the trial court to hold a restitution hearing. The trial court held a hearing and entered a restitution order for $1,976.55. The court of appeals concluded that the trial court's supplemental sentencing entry ordering restitution was void because the trial court lost jurisdiction to modify restitution when Defendant was released from prison. The Supreme Court affirmed, holding that the trial court lost any jurisdiction to modify the sentence when Defendant completed his sentence. View "State v. Brasher" on Justia Law

The Supreme Court held that a three-year prison term imposed under Ohio Rev. Code 2950.99(A)(2)(b) is to be imposed "in addition to" any prison term imposed under "any other provision of law," including a sentence imposed under Ohio Rev. Code 2929.14(A)(3)(b).In 2013, Defendant was convicted of unlawful sexual conduct with a minor. In 2018, Defendant was convicted of failing to provide a change of address notification for his sex offender registration, in violation of Ohio Rev. Code 2950.05(F)(1), and sentenced to serve three years and nine months in prison. On appeal, Defendant argued that section 2929.14(A)(3)(b) limited his possible sentence for a thirty-degree felony to a maximum of thirty-six months. The court of appeal affirmed Defendant's sentence. The Supreme Court affirmed, holding that, under the unambiguous language of section 2950.99(A)(2)(b), a trial court must impose a three-year prison sentence "in addition to" the sanctions imposes under section 2929.14. View "State v. Ashcraft" on Justia Law

The Supreme Court held that Ohio Rev. Code 2929.14(C)(4) requires trial courts to consider the overall number of consecutive sentences and the aggregate sentence to be imposed when making the necessity and proportionality findings required for the imposition of consecutive sentences and that appellate review of consecutive sentences under Ohio Rev. Code 2953.08(G)(2) does not require deference to the trial court's findings under section 2929.14(C)(4).At issue was whether Defendant's sixty-five-year aggregate sentence for numerous nonviolent felonies violated section 2929.14(C)(4), Ohio's consecutive sentencing statute, or the Eighth Amendment to the United States Constitution. The Supreme Court reversed the court of appeals' judgment affirming Defendant's sixty-five year sentence and remanded the case for further consideration in light of the Court's clarification on how sections 2929.14(C)(4) and 2953.08(G)(2) are to be applied, holding (1) consecutive sentence findings must be made in consideration of the aggregate term to be imposed; and (2) appellate review of consecutive sentences does not require appellate courts to defer to the sentencing court's findings. View "State v. Gwynne" on Justia Law