Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court dismissing the indictment in this case with prejudice, holding that the trial court properly dismissed the indictment but erred when it dismissed the indictment with prejudice.At issue was what constitutes adequate notice to inform a wholesale distributor that it is charged with drug trafficking under Ohio's drug-trafficking laws. The State charged Appellants, who were in the business of wholesale distribution, with drug trafficking for acting "not in accordance with Chapter 4729 of the Ohio Revised Code." The trial court granted Appellants' motion to dismiss on the grounds that the State failed to provide them with sufficient notice. The court of appeals reversed. The Supreme Court reversed, holding (1) in a drug-trafficking case against a wholesale distributor, the State must prove that the wholesale distributor failed to act in accordance with Chapter 4729; and (2) the State failed to identify the nature and cause of the accusation against Appellants, and therefore, the case must be dismissed without prejudice. View "State v. Troisi" on Justia Law

The Supreme Court granted a writ of mandamus ordering the Mahoning County Board of Elections to place Eric Ungaro's name on the November 2022 general election ballot as an independent candidate for the office of state representative, holding that Ungaro successfully established that he was entitled to the writ.Ungaro filed a statement of candidacy and nominating petition to run as an independent candidate for the office of state representative of the 59th Ohio House District in the November 2022 general election. The Board rejected the petition by a vote of three to one. Ungaro then filed this action seeking a writ of mandamus ordering the Board to place his name on the ballot. The Supreme Court affirmed, holding that the Board abused its discretion by invalidating Ungaro's petition in an arbitrary fashion. View "State ex rel. Ungaro v. Mahoning County Bd. of Elections" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's mandamus complaint for failure to satisfy the affidavit requirement of Ohio Rev. Code 2969.25(A), holding that Appellant failed to demonstrate any error in the court of appeals' judgment of dismissal.In 1993, Appellant was convicted of murder. In 2021, Appellant commenced this action seeking a writ of mandamus ordering the Ohio Adult Parole Authority to remove all incorrect information from his file and order a new parole hearing. The court of appeals dismissed the action after finding that Appellant's affidavit of prior actions was fatally deficient. The Supreme Court affirmed, holding that the court of appeals correctly dismissed this action for failure to comply with section 2969.25(A). View "State ex rel. Pointer v. Ohio Adult Parole Authority" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus sought by Appellant to compel Judge Julie M. Lynch to vacate certain nunc pro tunc entries, holding that Appellant was not entitled to the writ.Appellant was sentenced in 2003 on more than sixty felony counts involving crimes he committed in four separate cases. This appeal involved three cases that included offenses Appellant committed after postrelease control became part of Ohio's sentencing scheme in 1996. Prior to Appellant's release from prison in 2020, Judge Lynch issued the nunc pro tunc entries at issue, which corrected some of Appellant's sentencing entries to include references to the imposition of a mandatory five-year term of postrelease control. Appellant brought this action seeking a writ of mandamus to compel Judge Lynch to vacate the entries. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant did not have a clear legal right to relief in mandamus. View "State ex rel. Randlett v. Lynch" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the order of the trial court ordering forfeiture of Appellant's 2014 Chevrolet Silverado, holding that there was no equal protection violation and that, as applied to Appellant, the vehicle forfeiture did not violate the Excessive Fines Clause of the Eighth Amendment.Appellant entered a plea of no contest to one charge of operating a vehicle while intoxicated (OVI). Because Appellant had two prior OVI convictions within the preceding ten years, his vehicle was seized pending the completion of the proceedings. After a forfeiture hearing held pursuant to Ohio Rev. Code 4503.234 the trial court ordered Appellant to forfeit his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the statutory classification contained in Ohio Rev. Code 4511.19(G)(1)(c)(v) does not violate constitutional equal protection guarantees; and (2) the forfeiture of Appellant's vehicle was not grossly disproportional and was thus not unconstitutional as applied to Appellant. View "State v. O'Malley" on Justia Law

The Supreme Court held that in order for a person whose license is suspended for an offense for operating a vehicle while under the influence of alcohol or drugs (OVI) to be guilty of driving under an OVI suspension, the person must cause movement of a motor vehicle on the public roads or highways within this state during the period of the suspension.Because Defendant was in the driver's seat while a parked car was running and her license was suspended due to an OVI offense, the officer cited her for driving under a suspended license. The charge was later amended to reflect a violation of Ohio Rev. Code 4510.14 for driving under an OVI suspension. The trial court found Defendant guilty of driving under an OVI suspension. The court of appeals reversed, concluding that, in order for the state to prove the element of "operated" under section 4510.14(A), it must present sufficient evidence showing some movement of the vehicle. The Supreme Court affirmed, holding that, in order for a person whose license is suspended for an OVI offense to be guilty of driving under an OVI suspension, the person must cause or have caused movement of the motor vehicle on the public roads or highways within this state. View "State v. Wilson" 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 Appellee, the warden of Trumbull Correctional Institution, holding that the court of appeals properly dismissed the petition.After a jury trial, Appellant was convicted of murder and sentenced to a prison term of thirty-six years to life. His convictions and sentence were affirmed on appeal. Appellant later filed a petition for a writ of habeas corpus, arguing that he was entitled to relief because the jury's verdict was not unanimous. The court of appeals dismissed the petition, concluding that Appellant had an adequate remedy in the ordinary course of the law law by way of direct appeal to raise his claim. The Supreme Court affirmed, holding (1) Appellant had an adequate remedy at law by which to raise his jury-unanimity claim; and (2) the trial court's judgment was not void for lack of jurisdiction. View "Pope v. Bracy" 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 the court of appeals correctly found the petition to be procedurally defective under Ohio Rev. Code 2969.25(C) and 2725.04.Appellant was convicted of five counts of aggravated rape and sentenced to an aggregate prison term of twenty years to life. After he was released, Appellant was arrested by his parole officer for violating the conditions of his parole and found guilty of the charged violations. Appellant filed a petition for habeas corpus, arguing that his parole revocation hearing had been untimely. The court of appeals sua sponte dismissed the petition on the grounds that it failed to comply with the requirements of sections 2969.25(C) and 2725.04. The Supreme Court affirmed, holding that dismissal was proper in this case. View "State ex rel. Foster v. Foley" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the district court denying Defendant's motion to dismiss two of the charges against him, holding that toxicology results trigger a new speedy-trial period for charges premised on the commission of a per se operating a vehicle while under the influence of alcohol or drugs (OVI) offense.The State charged Defendant with one felony offense related to a car accident in which Defendant killed another driver and was held in jail pending indictment. The grand jury's indictment, however, included additional charges based on toxicology results that had not been available at the time of Defendant's arrest. At issue was whether the charges based on Defendant's drug-test results were subject to the same speedy-trial period as the original charge. The Supreme Court held (1) the test results were new information necessary to establish that Defendant operated a vehicle with a prohibited level of drugs in his system; and (2) therefore, the State was entitled to a new speedy-trial period for the charges premised on the per se OVI offense. View "State v. Sanford" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that dismissed counts in an indictment may be sealed before the conviction is eligible to be sealed, holding that the court of appeals erred.Defendant was indicted on multiple counts and plead guilty to one count. The State dismissed the remaining counts as part of a plea deal. Before he was eligible to have the record of his conviction sealed Defendant filed an application to seal, asserting that the trial court could seal the portions of the record pertaining to the dismissed charges pursuant to Ohio Rev. Code 2953.52. The trial court denied the application to seal. The court of appeals reversed. The Supreme Court reversed, holding that under the plain language of the statutes governing sealing, the dismissed counts in the indictment may not be sealed until the conviction is eligible to be sealed. View "State v. G.K." on Justia Law