Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the juvenile court to transfer Appellant to adult court, holding that that court's decision to transfer Appellant to adult court was not supported by a preponderance of the evidence and that the juvenile court abused its discretion by relinquishing jurisdiction.After the juvenile court transferred jurisdiction over Appellant to the general division a jury found Appellant guilty of aggravated murder and murder for a killing that occurred when he was fourteen years old. The court of appeals affirmed the conviction, concluding that the juvenile court did not violate Appellant's constitutional right to due process by transferring his case to the adult court. The Supreme Court reversed, holding (1) the standard of proof applicable to discretionary-bindover proceedings is a preponderance of the evidence, and the state need not produce affirmative evidence of nonamenability; (2) a juvenile court need not consider all potential juvenile dispositions when balancing the factors weighing in favor of and against transfer; and (3) the juvenile court improperly relinquished jurisdiction in this case. View "State v. Nicholas" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding Defendant's conviction of felony murder for a one-punch homicide, holding that Defendant failed to establish that his trial counsel provided ineffective assistance.Defendant killed an eighty-three-year-old man by punching him in the face, causing the victim to crash to the ground and strike his head on the concrete. After a jury trial, Defendant was found guilty of felony murder and felonious assault. On appeal, Defendant argued that his trial counsel was ineffective for failing to request jury instructions on lesser-included and inferior-degree offenses. The Supreme Court disagreed and affirmed, holding that Defendant failed to demonstrate that his counsel misunderstood the law or that he would have been entitled to additional jury instructions had his attorney requested them. View "State v. Lloyd" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated murder and his sentence of death, holding that, while error occurred in this case in the form of repetitive crime scene photos, the prosecutor's misstatements, and sentencing opinion errors, none of the errors resulted in prejudicial error.After a jury trial, Defendant was found guilty of the aggravated murders of his four-year-old daughter, C.D., and her mother, Nicole Duckson, with accompanying death-penalty specifications. The court sentenced Defendant according to the jury's recommendation of a sentence of death for the aggravated murder of C.D. The court then sentenced Defendant to life without parole for the aggravated murder of Nicole. The Supreme Court affirmed but remanded the case, holding (1) Defendant received a fair trial, and none of the errors in this case, when considered either individually or cumulatively, resulted in prejudicial error; (2) the overwhelming evidence established Defendant's guilt; and (3) the case must be remanded for the trial court to issue a nunc pro tunc entering confirming the September 14, 2019 judgment entry and the September 16, 2019 entry to the sentence that was imposed at the sentencing hearing. View "State v. Garrett" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions, entered upon his guilty plea, for involuntary manslaughter, having weapons while under a disability, and aggravated riot, holding that the juvenile court's probable cause determination was not subject to a manifest-weight challenge on appeal.The State filed a complaint in the juvenile court alleging that Defendant committed involuntary manslaughter and related offenses. The juvenile court determined that the State had established probable cause to believe that Defendant committed the offense and transferred Defendant's case to the general division. Defendant ultimately pled guilty. On appeal, Defendant argued that the juvenile court erred in transferring his case to the general division. The court of appeals affirmed. The Supreme Court affirmed, holding that a juvenile court's probable cause determination at a mandatory binder hearing is not subject to a manifest-weight review on appeal. View "State v. Martin" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals holding that a person adjudicated a juvenile delinquent may not reopen his or her direct appeal from the adjudication based on a claim of ineffective assistance of appellate counsel under App.R. 26(B).The juvenile division of the court of common pleas adjudicated T.A. a delinquent child. The Ninth District Court of Appeals affirmed. T.A. subsequently filed an application to reopen his direct appeal under App.R. 26(B). The Ninth District denied the application, concluding that a child adjudicated delinquent may not apply for reopening of his or her appeal from the adjudication under the rule. The Supreme Court affirmed, holding that App.R. 26(B) does not apply to juvenile adjudications. View "In re T.A." on Justia Law

The Supreme Court reversed the judgment of the court of appeals holding that the failure to have satisfied a condition of community control prevents a defendant from receiving a final discharge even after community control has been terminated, holding that the court of appeals erred.At issue was the point at which a defendant convicted of a felony attains a "final discharge" from a sentence of nonresidential community control for purposes of becoming eligible to apply to have the felony conviction sealed. The court of appeals concluded that the conditions of a defendant's nonresidential community-control sanction constitute sentencing requirements and that a defendant must satisfy all such requirements in order to receive a final discharge. The Supreme Court reversed, holding that when a defendant's nonresidential community control is terminated the defendant receives a final discharge from the community-control sanction. View "State v. P.J.F." on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's convictions and remanding the matter for a new trial, holding that the trial court did not violate Defendant's Sixth Amendment right to a public trial by partially limiting access to the courtroom after an altercation disrupted court proceedings.Defendant was indicted on two counts of murder. During a recess on the third day of trial, some of the people attending the trial were involved in an altercation outside the courtroom, which resulted in the court limiting attendees to only immediate family members. Defendant was subsequently found guilty of murder as a result of felonious assault. The court of appeals reversed, ruling that the trial court had committed structural error by failing to provide sufficient justification for the partial closure of the courtroom. The Supreme Court reversed, holding that a public trial violation occurred in Defendant's trial but that the error did not rise to the level of a plain error that must be corrected. View "State v. Bond" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court denying Appellant's motion for leave to file a motion for a new trial and a successive petition for postconviction relief without an evidentiary hearing, holding that the lower courts abused their discretion by applying res judicata to preclude Appellant's claims.In 1997, Appellant was convicted of aggravated burglary, kidnapping, rape, felonious assault, and theft. In 2018, Appellant discovered a memorandum that led him to file a motion for leave to file a motion for a new trial and a successive petition for postconviction relief. The trial court denied relief, concluding that res judicata barred Appellant's arguments because the memo was "not really new" evidence. The court of appeals affirmed. The Supreme Court reversed, holding that res judicata did not bar Appellant's motion or his petition. View "State v. Hatton" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Appellant's petitions for postconviction relief challenging his convictions in a rape case and a jail case, holding that there was no error.After a jury trial, Appellant was convicted of rape and kidnapping. While he was being held in jail on the rape charges, Appellant and two other inmates attacked one of their cellmates. A jury found Appellant guilty of felonious assault and kidnapping for the attack. Appellant later filed petitions for postconviction relief challenging his convictions in both cases. The trial court denied relief. The Supreme Court affirmed, holding (1) postconviction claims alleging a denial of the constitutional right to effective assistance of counsel are not procedurally barred if they cannot meaningfully be reviewed without resorting to evidence outside the trial record; and (2) all of Appellant's claims were either barred by res judicata or failed to set forth a substantive claim for relief. View "State v. Blanton" on Justia Law

The Supreme Court denied Petitioner's petition for a writ of habeas corpus against the warden of the Richland Correctional Institution, holding that Petitioner failed to attach his commitment papers, as required by Ohio Rev. Code 2725.04(D).Petitioner, an inmate at the institution, was serving a sentence for aggravated murder and other felonies. In his petition for a writ of habeas corpus Petitioner argued that the failure to accord him a parole hearing as required under the original sentencing entry. In his returned, the warden argued that the writ should be denied because Petitioner did not comply with section 2725.04(D). The Supreme Court agreed and denied the writ, holding that that affidavit attached to Petitioner's habeas petition did not offer a legitimate justification for Petitioner's failure to comply with section 2725.04(D). View "McDonald v. Black" on Justia Law