Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that Appellant was not entitled to relief on his allegations of error.Appellant was an adult when a complaint was filed charging him with delinquency in connection with a shooting death that occurred when Appellant was a minor. The juvenile court transferred Appellant to the adult court, where he was convicted of aggravated murder and other crimes. Appellant later filed a petition for a writ of habeas corpus, which the court of appeals dismissed. The Supreme Court affirmed, holding (1) Appellant failed to allege a jurisdictional defect in the juvenile court's transfer of his criminal case to the adult court; and (2) Petitioner had an adequate remedy in the ordinary course of law. View "State ex rel. Parker v. Black" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the court of appeals granting summary judgment against Appellant, an inmate seeking to compel the clerk of courts to produce certain records under the Public Records Act, Ohio Rev. Code 149.43, holding that the court of appeals erred in rejecting Appellant's statutory-damages claim.Appellant filed a complaint for writ of mandamus alleging that he sent ten public-records requests to the clerk of court, who did not respond. The court of appeals concluded that Appellant was not entitled to relief in mandamus because the only requested record that was subject to the Public Records Act was not properly requested. The Supreme Court reversed in part, holding that the court of appeals erred in its rejection of Appellant's statutory-damages claims on the ground that the requested documents were governed by the Rules of Superintendence. View "State ex rel. Ware v. Kurt" on Justia Law

The Supreme Court affirmed Defendant's convictions for, among other crimes, two counts of aggravated murder with four death-penalty specifications attached to each count and Defendant's sentence of death, holding that there was no reversible error.Specifically, the Supreme Court held (1) Defendant's argument that the Ohio Constitution limits the right to self-representation was not well taken; (2) Defendant failed to show plain error as to his argument that his standby counsel interfered with his trial preparation and strategy; (3) the evidence was sufficient to support the convictions; (4) there was no abuse of discretion in jury selection; (5) the court did not admit inadmissible victim-impact testimony from witnesses during the trial phase or commit other reversible evidentiary error; (6) there was no prosecutorial misconduct or ineffective assistance of counsel; and (7) Defendant's remaining assignments of error were unavailing. View "State v. McAlpin" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus, holding that Appellant did not show that the parole-revocation proceedings violated his constitutional right to due process.Appellant was convicted of aggravated murder and aggravated robbery and was later released on parole. Appellant was subsequently charged with violating the terms of his parole. After a revocation hearing, the parole board approved the hearing officer's recommendation that Appellant be ordered to serve an additional thirty-six months in prison before again becoming eligible for parole. The parole board approved the recommendation. Appellant filed an action for a writ of mandamus alleging that he was denied the effective assistance of counsel and that reversible error occurred during the revocation hearing. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant failed to show that the parole revocation proceedings violated his constitutional right to due process. View "State ex rel. Mango v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions, holding that the judge's comments and questions to witnesses during Defendant's criminal trial did not violate Defendant's right to a fair trial before an impartial judge.After a trial, Defendant was found guilty of felonious assault and associated firearm specifications and of having a weapon while under a disability. The court of appeals affirmed. On appeal, Defendant argued that his due process right to a fair trial was violated because the trial court engaged in questioning that showed bias against him. The Supreme Court affirmed, holding that Defendant did not carry his burden of establishing a reasonable probability that but for the judge's actions he would not have been found guilty of the charged offenses. View "State v. West" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals upholding Defendant's conviction of involuntary manslaughter, holding that Defendant's argument on appeal was without merit.Defendant committed a felony when he fired his gun at the scene of a fatal shooting because he was under disability as a result of a prior, unrelated drug offense that prohibited him from having or using a firearm. On appeal, Defendant argued that his prior drug offense that formed the basis for his firearms disability was unrelated to the victim's death, and therefore, his involuntary manslaughter conviction was improper. The Supreme Court affirmed, holding that, by its plain terms, Ohio Rev. Code 2903.04(A) simply requires that a person cause the death of another "as a proximate result" of the commission of a felony. View "State v. Crawford" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing Defendant's convictions after finding that the state failed to prove venue, holding that the court of appeals did not err.Defendant was indicted in Erie County for retaliation, attempted aggravated murder, and conspiracy arising from conversations that he had with his cellmate while he was incarcerated in Marion County. Defendant objected to venue and requested that the proceedings be transferred to Marion County, but the motion was summarily denied. A jury then found Defendant guilty of all three charges. The court of appeals reversed, concluding that venue was improper in Erie County. The Supreme Court affirmed, holding that the State failed to prove that venue was proper in Erie County. View "State v. Moore" on Justia Law

The Supreme Court held that the general division of a common pleas court does not have jurisdiction over an offender who was arrested at the age of twenty for felonious acts he allegedly committed as a juvenile.Appellant was arrested at the age of twenty for acts he allegedly committed when he was seventeen years old, acts that would have been felonious had they been committed by an adult. Appellant was first indicted in the general division of the court of common pleas. The State recognized that the general division did not have jurisdiction over Appellant under Ohio Rev. Code 2152.02(C)(3) and 2151.23(I) and moved to dismiss the indictment. The indictment was dismissed, but because Appellant was twenty-two years old at that point, the State reindicted him in the general division the next day. The court of appeals affirmed. The Supreme Court reversed, holding that the jurisdiction of the general division of the court of common pleas is not invoked when a person is arrested at the age of twenty for felonious acts that he allegedly committed as a juvenile. View "State v. Hudson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the judgment of the trial court finding Robert Burns strictly liable as a public official for the misappropriation of public money, holding that Burns was not strictly liable for the embezzled funds.Burns contracted with New City Community School, a charter school, to be its chief executive officer, and Carl Shye was an independent contractor hired by New City to be the school's treasurer. After the auditor of state concluded that more than $50,000 of New City's state and federal grants had been misappropriated the Attorney General filed a complaint against Burns, Shye, and other defendants, alleging that they were jointly and severally liable as public officials. The trial court found Burns strictly liable. The Supreme Court reversed, holding that Burns was not strictly liable for the embezzled funds because he did not receive or collect the public money that was misappropriated. View "State ex rel. Yost v. Burns" on Justia Law

The Supreme Court affirmed the court of appeals' decision affirming the judgment of the trial court dismissing the criminal case against Defendant without prejudice, holding that the trial court did not err when it denied the State's requests to issue a material-witness warrant.The court of appeals concluded that the trial court properly denied the State's requests to issue the material-witness warrants because the State failed to demonstrate probable cause that warrants were necessary to procure the witnesses' attendance at trial. The Supreme Court affirmed, holding (1) when the State requests that a court issue a material-witness warrant it must establish, by either oath or affidavit, probable cause to believe that the witness is material and that the warrant is necessary to procure the witness's attendance at trial; and (2) the trial court did not err in this case. View "State v. Eatmon" on Justia Law