Justia Criminal Law Opinion Summaries

In a case before the Supreme Court of Ohio, the defendant was accused of setting up a fake car sale, during which he threatened two women with a gun and stole money. The defendant was convicted of robbing both women and illegally possessing a firearm. On appeal, the First District Court of Appeals overturned these convictions, arguing that the defendant could not be convicted of robbing the woman who was not directly holding the money. Furthermore, the court held that the defendant's rights were violated when the state used information at trial that was not previously disclosed to the defense.The Supreme Court of Ohio reversed the lower court's decision. Firstly, the court clarified that under the state's robbery statute, a person can be convicted of robbery if they commit a theft offense and threaten physical harm to another person, even if the person threatened is not the same as the theft victim. As such, both women were properly considered as victims of robbery. Secondly, the court determined that the defendant had forfeited his claim to a violation of his rights, as he failed to raise the issue of undisclosed evidence at the trial level.The case was remanded back to the First District Court of Appeals to consider the defendant's remaining assignments of error. View "State v. Brown" on Justia Law

In the case of State v. Nicholson, the Supreme Court of Ohio affirmed the defendant's convictions and death sentences for the aggravated murders of two individuals. The court found that the evidence was sufficient to support the convictions, as it demonstrated that the defendant acted with prior calculation and design. Additionally, the court found no error in the trial court's decision to admit certain evidence, such as photographs from the crime scene and testimonies about the defendant's relationships with the victims. Furthermore, the court rejected the defendant's arguments regarding the adequacy of the jury instructions and the admission of victim-impact evidence, among other issues. The court concluded that the defendant did not establish any grounds for reversal of his convictions or sentences. View "State v. Nicholson" on Justia Law

In this case, the Supreme Court of Ohio considered whether a juvenile, T.D.S., knowingly, intelligently, and voluntarily waived his Miranda rights before providing statements to the police. The statements related to a homicide investigation involving another juvenile.The case originated from an incident in 2019, where the Police responded to a report of shots fired in an apartment building and discovered a male juvenile, S.G., with gunshot wounds. The police investigation led them to T.D.S., who was then 15 years old. During questioning at T.D.S.'s mother’s house, T.D.S. initially denied involvement in the shooting but later admitted to accidentally shooting S.G. while playing with a gun. After these statements, T.D.S. was read his Miranda rights and questioned further. He was subsequently charged with several offenses including murder and felonious assault.T.D.S. argued that the juvenile court should have granted a motion to suppress all the statements he made to the police officers, contending that he did not knowingly, intelligently, and voluntarily waive his Miranda rights. After considering the totality of the circumstances, including T.D.S.'s age, prior criminal experience, and the nature of the police interrogation, the Supreme Court of Ohio affirmed the lower courts' decisions that T.D.S. had knowingly, intelligently, and voluntarily waived his Miranda rights. The court found that the police did not engage in coercion and that T.D.S.'s waiver was not involuntary.T.D.S. also argued that his post-Miranda statements should be presumed inadmissible under the court's previous reasoning in a case called State v. Farris. However, the court found that T.D.S. had not properly raised this argument in the lower courts, so it was forfeited. Even if he had preserved the argument, the court found that the record did not support his claims under the Farris case.Therefore, the court affirmed the judgment of the lower courts, finding that T.D.S.'s post-Miranda statements were properly admitted at trial. View "In re T.D.S." on Justia Law

In December 2019, a taxicab driver, Phillip Palmer, shot a heavily intoxicated passenger, Nicholas Young, following a dispute over cab fare. The incident escalated into a physical altercation at a gas station, where Young shoved Palmer twice, causing him to fear for his life. Palmer, who had begun carrying a gun in his cab after hearing about a driver who had been shot by a passenger, fired two shots at Young, hitting him in the neck. Young survived his injuries. At trial, Palmer admitted to the shooting but claimed self-defense. The trial court denied Palmer's request for a self-defense jury instruction, finding Palmer's statements about his means of escape not credible and determining that a reasonable person would not have believed they were in danger of being killed by Young under the circumstances. Palmer was acquitted of attempted murder but found guilty of felonious assault and a firearm specification.The Supreme Court of Ohio reversed the decision of the Twelfth District Court of Appeals, which had affirmed the trial court's judgment. The Supreme Court determined that the trial court had improperly weighed the evidence when performing a sufficiency analysis. The court found that Palmer had presented legally sufficient evidence for each element of self-defense and was therefore entitled to a self-defense jury instruction. The evidence presented, if believed, could convince a trier of fact that Palmer was acting in self-defense. Therefore, the case was remanded for a new trial on the felonious-assault charge and accompanying firearm specification. View "State v. Palmer" on Justia Law

The case involves appellant Soleiman Mobarak, who appealed the judgment of the Tenth District Court of Appeals dismissing his petition for a writ of mandamus against appellee, Franklin County Court of Common Pleas Judge Jeffrey M. Brown. Mobarak had sought to vacate his criminal convictions for lack of subject-matter jurisdiction in the trial court. The court of appeals held that the trial court had jurisdiction over Mobarak’s criminal case and that Mobarak had an adequate remedy in the ordinary course of the law.In 2012, Mobarak was indicted on charges of engaging in a pattern of corrupt activity, aggravated trafficking in drugs, and aggravated possession of drugs. The charges alleged that Mobarak had possessed and sold a controlled-substance analog commonly known as bath salts. In his petition, Mobarak asserted that the trial court lacked subject-matter jurisdiction over his criminal case on several grounds including that there was no statute prohibiting the possession or sale of bath salts at the time his offenses were alleged to have occurred, and that the controlled-substance-analogs law was unconstitutionally vague.The Supreme Court of Ohio affirmed the Tenth District Court of Appeals' judgment dismissing Mobarak’s petition. The court held that Mobarak’s petition failed to state a mandamus claim because he had an adequate remedy in the ordinary course of the law and failed to show that the trial court had patently and unambiguously lacked jurisdiction over his criminal case. The court found that by virtue of the Ohio Constitution and R.C. 2931.03, the trial court had jurisdiction over Mobarak’s criminal case. The court also noted that Mobarak’s arguments were similar to those raised and rejected in his prior appeals. The court stated that extraordinary writs may not be used as a substitute for an otherwise barred second appeal or to gain successive appellate reviews of the same issue. View "State ex rel. Mobarak v. Brown" on Justia Law

The case involves an appeal by an inmate, Keith Walker, against the Third District Court of Appeals' dismissal of his request for a writ of mandamus. Walker had been convicted of misdemeanor domestic violence in 2020, for which he received the maximum sentence allowed by law. He later filed a motion to vacate his guilty plea, arguing that the plea and the judgment of conviction were void due to the absence of a judge at his plea hearing, and the prosecutor's alleged role in accepting his plea and sentencing him. The municipal court judge, Teresa Ballinger, denied his motion. Walker then filed a complaint for a writ of mandamus, asking that his conviction be vacated as an illegal and void judgment. This was dismissed by the Third District Court of Appeals, who agreed with Judge Ballinger's argument that Walker had failed to submit an affidavit required by R.C. 2969.25(A), and that his claim was not cognizable in mandamus.On appeal, the Supreme Court of Ohio held that the Third District Court of Appeals was incorrect to dismiss the action based on a failure to comply with R.C. 2969.25(A)’s affidavit requirement, as the statute does not require a statement that the inmate has filed no such civil action or appeal. However, the Supreme Court agreed with the lower court's determination that Walker's claim was not cognizable in mandamus, as his argument essentially raised a nonjurisdictional defect for which he had an adequate remedy in the ordinary course of law. Therefore, the Supreme Court affirmed the judgment of the Third District Court of Appeals dismissing Walker's complaint. View "State ex rel. Walker v. Ballinger" on Justia Law

In this case, the appellant, Eric Johnson, filed a third, untimely, and successive petition for postconviction relief based on an affidavit from the victim, James Keith, who recanted his identification of Johnson as the assailant. Johnson argued that he was unavoidably prevented from discovering Keith's recantation before the statutory deadline and that, but for constitutional error at trial, he would not have been convicted. However, the Supreme Court of Ohio upheld the decisions of the lower courts, denying Johnson's petition for postconviction relief. The court held that Johnson failed to provide sufficient evidence to prove that he was unavoidably prevented from discovering Keith's recantation within the statutory deadline. The court also held that Johnson failed to show that a constitutional error occurred at trial that led to his conviction. Specifically, the court stated that a conviction based on false testimony is not a constitutional violation unless the state had knowledge of the testimony’s falsity. The court therefore concluded that Johnson did not satisfy the requirements for filing an untimely or successive petition for postconviction relief under R.C. 2953.23(A)(1). View "State v. Johnson" on Justia Law

In the case before the Supreme Court of Ohio, the issue concerned whether a landlord or landlord's agent can prohibit a person from entering leased premises, even if that person has received permission from a tenant. The case arose when Antonio Randolph was banned from an apartment complex by the property manager and was then later arrested and charged with criminal trespass after he was discovered in his uncle's apartment at the complex, which his uncle had invited him to. The trial court found Randolph guilty of criminal trespass. The Sixth District Court of Appeals reversed the trial court's judgment, holding that the city had to prove that Randolph had entered the premises without privilege, and that his uncle's invitation to the apartment contradicted this.Upon review, the Supreme Court of Ohio agreed with the Sixth District's decision. The court held that a landlord or landlord's agent generally may not exclude a person from rented premises such that the excluded person is considered a trespasser when on the premises even if the person received permission to enter the premises from a tenant of the property. The court noted that Ohio law provides that a landlord cedes his or her possessory interests in leased property to the tenant and therefore may not prohibit the tenant from inviting guests onto the property.However, the court also highlighted that a landlord can maintain control over access to a property if the landlord so desires, provided that this authority is reserved in the lease agreement. In the absence of such a provision in the lease agreement, a tenant may invite onto the property a person whom the landlord has sought to ban from the premises. The judgment of the Sixth District Court of Appeals was affirmed. View "State v. Randolph" on Justia Law

In this case, an appellant challenged his criminal convictions, arguing that the trial court had erred by failing to hold a competency hearing. The appellant's counsel had requested a competency evaluation prior to the trial, but the appellant refused to be transported to the treatment center for the evaluation. The Supreme Court of Ohio held that while the trial court should have held a competency hearing, the error was harmless because the record, when viewed as a whole, did not demonstrate sufficient indicia of incompetency. The court noted that the appellant had demonstrated understanding of the proceedings and had been able to articulate what his counsel had told him about the proceedings. Therefore, the court affirmed the decision of the lower court, upholding the appellant's convictions. View "State v. Mills" on Justia Law

In the case before the Supreme Court of Ohio, Michael Swazey Jr. was indicted for failing to pay child support. He filed a pretrial motion to dismiss the indictment under Rule 12(C)(2) of the Ohio Rules of Criminal Procedure, arguing that the statutes he allegedly violated did not apply to him. The trial court declined to consider Swazey's motion on the merits, holding that the arguments raised were not permitted under Rule 12(C)(2) but should instead be presented at the close of the state’s case at trial. Swazey subsequently pleaded guilty to all counts.On appeal, the Ninth District Court of Appeals held that Swazey’s Rule 12(C)(2) motion was proper and should have been considered on the merits. It also held that by entering a guilty plea, Swazey did not waive his right to raise a constitutional challenge on appeal.The Supreme Court of Ohio affirmed the court of appeals' decision, stating that Swazey's motion to dismiss was appropriate under Rule 12(C)(2), and that his guilty plea did not waive his right to raise his constitutional challenge on appeal. Therefore, the Supreme Court of Ohio remanded the case back to the trial court to consider Swazey's pretrial motion. View "State v. Swazey" on Justia Law