Justia Criminal Law Opinion Summaries

The Supreme Court held that Defendant's sentence constituted cruel and unusual punishment under the Eighth and Fourteenth Amendments to the United States Constitution and Ohio Const. art. I, 9 when he was convicted as a juvenile and the trial court failed to consider his youth as a mitigating factor in sentencing.Defendant was charged with allegedly committing acts which, if committed by an adult, would constitute the offense of complicity to aggravated murder and other crimes. After a jury trial, Defendant was found guilty of several charges, and the trial court sentenced him to an indefinite life sentence in prison with parole eligible after thirty-eight to forty-three years. The Supreme Court reversed, holding that the trial court's sentence was unconstitutional because the court failed to consider Defendant's youth as a factor in sentencing. View "State v. Morris" on Justia Law

The Supreme Court reversed the portion of the judgment of the court of appeals affirming Appellant's conviction on count twenty-nine of the indictment and vacated that conviction and affirmed the portion of the judgment affirming Defendant's convictions on counts eleven, twenty, forty-five, forty-six, and fifty-five of the indictment, holding that, based on State v. Smith, 194 N.E.3d 197 (Ohio 2022), the adult court lacked subject matter jurisdiction over count twenty-nine.In Smith, the Supreme Court held that a finding of probable cause is a jurisdictional prerequisite under Ohio Rev. Code 215.212 to transferring a child to adult court for prosecution. In the instant case, Appellant argued that the adult court lacked subject-matter jurisdiction over count twenty-nine of the indictment because the juvenile court did not find probable cause to believe that Appellant had committed the act charged in that count. The Supreme Court agreed and reversed the court of appeals' decision affirming Appellant's conviction on count twenty-nine and otherwise affirmed, holding that Appellant's remaining claims of error were without merit. View "State v. Burns" on Justia Law

The Supreme Court reversed the opinion of the the court of appeals affirming the trial court's denial of Defendant's motion to suppress evidence recovered as a result of a constitutionally-defective search warrant, holding that the good-faith exception to the exclusionary rule did not apply to the search of cell phones in this case.At issue was a constitutionally-deficient search warrant authorizing the search of cell phones found at the scene of a car crash. Nothing in the affidavit connected the cell phones to the accident except a police officer's averment that evidence of how the accident occurred may be found on the phones. The court of appeals affirmed the denial of Defendant's motion to suppress for lack of probable cause, upholding the cell-phone search under the good faith exception to the exclusionary rule. The Supreme Court reversed, holding (1) the warrant was constitutionally defective for want of probable cause in the warrant's supporting affidavit; and (2) the good-faith exception to the exclusionary rule did not apply. View "State v. Schubert" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals ruling that the state's rebuttal of a defendant's claim of self-defense is not subject to review under the sufficiency-of-the-evidence standard, holding that the state's new burden of disproving the defendant's self-defense claim beyond a reasonable doubt is subject to a manifest-weight review on appeal.After a jury trial, Defendant was convicted of murder and felony murder and sentenced to eighteen years to life in prison. On appeal, Defendant argued that the state had not presented legally sufficient evidence to establish that he had not acted in self-defense and that the state had failed to disprove self-defense under a "manifest weight" standard. The court of appeals rejected Defendant's claims and affirmed. The Supreme Court affirmed, holding (1) the 2018 Am.Sub.H.B. No. 228 amendments to Ohio Rev. Code 2901.05 did not eliminate Defendant's burden of production regarding a claim of self-defense; (2) the state's new burden of disproving a self-defense claim beyond a reasonable doubt is subject to a manifest-weight review on appeal; and (3) the court of appeals did not err in declining to review the state's rebuttal of self-defense for sufficiency of the evidence. View "State v. Messenger" on Justia Law

The Supreme Court reversed the judgment of the court of appeals finding that the trial court did not abuse its discretion by denying Defendant's request to enter a plea of no contest on the ground that the court did not believe there were any legitimate issues to raise on appeal, holding that the trial court abused its discretion.Defendant was indicted on five drug-related counts. Defendant informed the court that he wished to proceed with a no-contest plea, but the trial court denied Defendant's request on the ground that there was no legitimate issue for appeal. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court abused its discretion by denying Defendant's request to enter a no-contest plea based on its own review of the appealable issues. View "State v. Hill" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the trial court denying Defendant's motion to withdraw his guilty plea, holding that Defendant had a reasonable and legitimate basis to withdraw his guilty plea.Pursuant to a plea deal from the state, Defendant pleaded guilty to involuntary manslaughter. Defendant subsequently filed a motion to withdraw his guilty plea, asserting that his attorneys did not review all the discovery with him. The trial court denied the motion, and the court of appeals affirmed. The Supreme Court reversed, holding (1) a defendant has a reasonable and legitimate basis to withdraw his guilty plea when, before sentencing, he discovers evidence that his attorney withheld from him and that would have negated his decision to plead guilty had he known about it; and (2) the trial court erred by not granting Defendant's motion to withdraw his guilty plea. View "State v. Barnes" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for three abduction charges, holding that the State erred in failing to provide Defendant with a bill of particulars in this case.Defendant was indicted for the abduction of his grandchildren who lives and stayed with him after his unmarried daughter died. Defendant requested a bill of particulars to understand how his actions constituted the offense of abduction. The State, however, refused to provide one, and twice the trial court refused to compel the State to provide one. The Supreme Court vacated Defendant's conviction, holding that the State fell short of what is required under the Constitution by not giving Defendant notice of exactly what it was alleging he did that could have constituted the offenses charged. View "State v. Haynes" on Justia Law

The Supreme Court held that if an offender who is on community control is convicted and imprisoned for a new offense, the revocation proceeding in the original case may not result in a prison sentence that runs consecutively to the new prison sentence if no mention was made of consecutive sentences as part of the original sentence for community control.Defendant pled guilty in Harrison County to endangering children. The trial court sentenced her to five years of community control with a two-year prison sentence reserved. Later, the trial court revoked Defendant's community control based on Defendant's conviction for robbery in a Jefferson County case, for which she had received a term of three years' imprisonment. The trial court ordered Defendant to serve the reserved two-year sentence consecutively to the three-year sentence imposed in the Jefferson County case. The court of appeals vacated the sentence. The Supreme Court affirmed, holding that the trial court was not authorized to impose a consecutive prison term on Defendant because she was not advised that if she violated the terms of her community control, she might be ordered to serve the two-year reserved prison term consecutively to any other sentences. View "State v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing the original action filed by Appellant seeking a writ of mandamus to compel the trial court to permit Appellant to independently test a certain evidence sample taken from the crime scene, holding that there was no error.In this action arose out of a capital murder case pending before the county court of common pleas the trial court granted the State's motion to permit DNA testing of an evidence sample that would consume the entire sample. Appellant, the defendant in the case, filed an original action seeking a writ of mandamus to compel the trial court to permit Appellant to independently test the sample. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that Appellant failed to comply with Ohio Rev. Code 2969.25(C). View "State ex rel. Swopes v. McCormick" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's sentences in connection with his conviction for robbery, kidnapping, abduction and rape, holding that the plain error doctrine was not properly applied by the court of appeals.Defendant was convicted following a jury trial. For purposes of sentencing, the trial court merged the abduction and kidnapping counts but concluded that the kidnapping and rape counts did not merge. Defendant did not object at sentencing to the trial court's failure to merge the kidnapping and rape counts. The court of appeals reversed, concluding that the trial court committed plain error by failing to merge the kidnapping and rape counts, which were allied offenses of similar import. View "State v. Bailey" on Justia Law