Justia Criminal Law Opinion Summaries

The Supreme Court held that 2018 Am.Sub.H.B. 228, which shifted the burden of proof on self-defense to the prosecution, applies to all trials conducted on or after its effective date of March 28, 2019, irrespective of when the underlying alleged criminal conduct occurred.On September 20, 2018, Appellant was indicted for aggravated burglary and other crimes. After a jury trial, Appellant was convicted. On appeal, Appellant argued that she was deprived of a fair trial when the trial court required her to bear the burden of proving that she had acted in self defense. The court of appeals affirmed, holding that the trial court had properly instructed the jury because the burden-shifting changes to Ohio Rev. Code 2901.05 did not apply retroactively. The Supreme Court reversed, holding that H.B. 228 must be applied to all pending and new trials that occur on or after its effective date of March 28, 2019. View "State v. Brooks" 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 Marion Correctional Institution, holding that there was no error or abuse of discretion.Appellant was convicted of four counts of aggravated murder and sentenced to two consecutive terms of life in prison without the possibility of parole for the murders. Appellant later filed a petition for a writ of habeas corpus alleging errors in the grand jury process that led to his indictment. The court of appeals dismissed the petition. The Supreme Court affirmed and denied Appellant's motion for an order compelling the Mahoning County Clerk of Courts to submit the complete record of his underlying criminal case for consideration on appeal, holding that the court of appeals properly dismissed Appellant's petition for failure to state a claim upon which relief could be granted. View "State ex rel. Barnette v. Hill" on Justia Law

The Supreme Court reversed the judgment of the trial court finding Defendant guilty of kidnapping and rape and a repeat-violent-offender specification and imposing a ten-year sentence on each count, to be served concurrently, holding that the trial court denied Defendant his constitutional right to a fair jury as guaranteed by the Sixth and Fourteenth Amendments to the United States Constitution.At issue was whether Defendant's right to a fair trial was violated when the alleged victim was introduced to the jury as the State's designated representative and was permitted to sit at counsel table with the prosecutor during the proceedings. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court erred in designating the alleged victim as the State's representative and by allowing her to sit at the prosecutor's table and that the error was not harmless, requiring reversal. View "State v. Montgomery" on Justia Law

The Supreme Court denied relief in this original action brought by Relator, an inmate at the Toledo Correctional Institution (TCI), brought seeking a writ of mandamus to fulfill his public records request he previously made to the records custodian for TCI (Respondent), holding that Relator was not entitled to the writ.In her affidavit, Respondent denied that TCI had any records requested by Relator. Respondent then brought this mandamus action. The Supreme Court denied the writ, holding that Relator requested information other than records, and therefore, he was not entitled to a writ or to his requested statutory damages. View "State ex rel. Griffin v. Sehlmeyer" on Justia Law

The Supreme Court determined that a warrantless search conducted in this case did not comport with the Fourth Amendment under the "single-purpose-container exception" to the warrant requirement, holding that when police search a bookbag in a home under circumstances that do not give rise to any exigency they must first obtain a warrant.After he was charged with illegal possession of drugs Defendant filed a motion to suppress, arguing that the warrantless search of the book bag conducted by a law enforcement officer was unlawful. The trial court denied the motion, concluding that the warrantless search was lawful because the book bag was in plain view and the officer had probable cause to suspect it contained contraband. The court of appeals affirmed. The Supreme Court reversed, holding (1) absent exigent circumstances, the search of a closed container requires a warrant; and (2) the single-purpose-container exception to the warrant did not apply in this case because a bookbag is not a single-purpose drug container. View "State v. Burroughs" on Justia Law

The Supreme Court reversed the judgment of the court of appeals upholding Defendant's sentence, holding that a defendant's display of disrespect toward a trial court is not a permissible sentencing factor that the court may consider under Ohio Rev. Code 2929.11 and 2929.12.The trial court in this case increased Defendant's prison sentence by six years in response to Defendant's misbehavior while reacting to the length of a previously-imposed prison sentence. The court of appeals affirmed. The Supreme Court reversed, holding (1) a defendant's outburst or other courtroom misbehavior may not result in an increased sentence for the underlying crime; and (2) the six-year increase in Defendant's sentence was contrary to law. View "State v. Bryant" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's action seeking a writ of mandamus ordering the trial court to hold a new sentencing hearing, holding that the court of appeals correctly dismissed the mandamus petition.Appellant was convicted of child endangering and felony murder. The trial court merged the offenses and determined that the sentences should run concurrently. Appellant later moved to vacate the "void sentences." The court of appeals concluded that the judgment of conviction was void because only one sentence could be imposed for the merged offenses. On remand, the trial court modified the sentence. Appellant subsequently brought this mandamus action asking the court of appeals to order the trial court to vacate its previous judgment and hold a new sentencing hearing. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant's appeal of the modified sentencing order constituted an adequate remedy in the ordinary course of law. View "State ex rel. Cherry v. Bryant" 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 the current prison warden for failing to state a claim upon which relief could be granted, holding that there was no error.Appellant pleaded guilty to several crimes, including two counts of gross sexual imposition and one count of rape. Appellant later filed a petition for a writ of habeas corpus, claiming that the trial court lacked jurisdiction to accept his plea and sentence him because his competency had been called into question. The court of appeals granted the warden's motion to dismiss. The Supreme Court affirmed, holding that habeas corpus will not lie in this case. View "Rance v. Watson" on Justia Law

The Supreme Court granted in part and denied in part a writ of mandamus ordering the Ohio Department of Rehabilitation and Correction (DRC) to provide certain records that Relator requested under the Public Records Act, Ohio Rev. Code 149.43, holding that Relator was entitled to a writ of mandamus compelling DRC to produce inmate master file documents.After Relator's request for documents was denied he commenced this action seeking a writ of mandamus compelling DRC to provide a copy of his inmate master file and all kites, grievances and appeals filed by him through the electronic-kite system. The Supreme Court granted the writ in part, holding (1) Relator failed to show a clear legal right to a writ of mandamus to compel the produce of the grievance-related records; (2) the DRC must produce the requested records; and (3) Relator was entitled to an award of the statutory maximum of $1,000 in damages. View "State ex rel. Mobley v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and/or procedendo against Franklin County Common Please Court Judge Carl A. Aveni II, holding that mandamus nor procendendo did not lie where Appellant had an adequate remedy in the ordinary course of the law.Appellant was found guilty of felony murder and felonious assault and sentenced to an aggregate prison term of twenty-five years to life. Appellant later filed the underlying complaint alleging that he was entitled to a new sentencing entry because the sentencing entry did not identify the felony underlying his felony-murder 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 that he could have pursued in the ordinary course of the law. View "State ex rel. White v. Aveni" on Justia Law