Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the decision 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 his motion for a new trial and finding that it lacked jurisdiction to consider Appellant's successive postconviction petition, holding that there was no error in the proceedings below.Appellant was convicted of two counts of aggravated murder and sentenced to death. Appellant later filed a motion for leave to file a motion for a new trial, claiming that the prosecution violated Brady v. Maryland, 373 U.S. 83 (1963). In a second filing, Appellant both submitted a successive petition for postconviction relief and moved for a new trial. The trial court denied all relief. The Supreme Court affirmed, holding (1) the trial court correctly dismissed Appellant's successive postconviction petition for lack of subject matter jurisdiction; and (2) Appellant's failure to meet his burden under Ohio Rev. Code 2953.23(A)(1)(b) required denial of Appellant's motion for leave to file a motion for a new trial. View "State v. Bethel" on Justia Law

The Supreme Court affirmed the judgment of the Eleventh District Court of Appeals dismissing Appellant's declaratory judgment and habeas claims but transferring his mandamus claim to the Tenth District Court of Appeals, holding that there was no error.Appellant, an inmate, filed an original action asserting that the revocation of his parole violated his rights to due process, free speech, and equal protection. Appellant sought a declaratory judgment of wrongful imprisonment, a writ of habeas corpus ordering his release from prison, and a writ of mandamus ordering the warden and the chair of the parole board to comply with established controlling law. The Eleventh District dismissed all but the mandamus claim then transferred the action to the Tenth District. The Supreme Court affirmed, holding that Appellant's potential remedy lay in mandamus. View "State ex rel. Guthrie v. Fender" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court denying Petitioner's request for injunctive and declaratory relief claiming that the application of Ohio Rev. Code 2969.271 to his conduct violated his rights under the First and Fourteenth Amendments to the United States Constitution, holding that the lower courts erred.Section 2969.271 allows the Ohio Department of Rehabilitation (DRC) and Correction to administratively extend an incarcerated defendant's prison term beyond his minimum prison term or presumptive earned early-release date but not beyond his maximum prison term. Petitioner entered Alford pleas to attempted burglary and other offenses. The trial court imposed a sentence under the "Reagan Tokes Law." On appeal, Petitioner argued that the sections of the statute allowing DRC to extend his prison term beyond the presumptive minimum term was unconstitutional. The court of appeals concluded that Petitioner's constitutional challenge was not ripe for review. The Supreme Court reversed, holding that a criminal defendant's challenge to the constitutionality of section 2969.271 is ripe for review on the defendant's direct appeal of his conviction and prison sentence. View "State v. Maddox" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus to compel the City of Beachwood to terminate special prosecutor Stephanie Scalise, holding that this case was moot.Burkons was charged with one count of interfering with civil rights. City Prosecutor Nathalie Supler moved for leave to withdraw as counsel due to a conflict of interest because Burkons was a city council member. Supler asked the trial court to appoint Scalise as special prosecutor in this case. The municipal court judge granted the motion. Burkons eventually filed a complaint in mandamus against the City challenging Scalise's "unauthorized representation of the City." The court of appeals dismissed the mandamus action. The days earlier, a writ of prohibition was issued halting the criminal case against Burkons based on improper venue. The Supreme Court affirmed the dismissal of Appellant's mandamus complaint, holding that this action was moot. View "State ex rel. Burkons v. Beachwood" on Justia Law

The Supreme Court denied requests sought by four Summit County Municipal Court judges for writs of prohibition and mandamus against Respondents, the Summit County Court of Common Pleas and its administrative judge, holding that that Plaintiffs failed to establish that they were entitled to the writs.The office of the county executive asked the municipal court judges at issue to stop appointing counsel for indigent unindicted felony defendants, concluding that municipal court appointments of private counsel were a misuse of public funds when representation was already provided for in contracts with the Legal Defender Office. Plaintiffs filed a complaint for writs of mandamus and prohibition to prevent the appointment of counsel by the common pleas court judges while a case is pending in the municipal court. The Supreme Court denied the writ, holding that municipal court judges have not established that common pleas court judges are in fact making such appointments appointments and that nothing in the local rules clearly states that common pleas court judges may do so. View "State ex rel. McKenney v. Jones" 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 Leon Hill, warden of the Marion Correctional Institution, holding that there was no error.Appellant was convicted and sentenced for aggravated robbery and felony murder. Appellant later filed a petition for a writ of habeas corpus, alleging that his convictions were nullities and that he should be immediately released. The court of appeals dismissed the petition. The Supreme Court affirmed, holding (1) the court of appeals correctly dismissed Appellant's petition on the basis of res judicata; and (2) Appellant's second proposition of law was without merit. View "Boler v. Hill" 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 properly dismissed the petition.Appellant was convicted on multiple counts of rape, kidnapping, and felonious assault and sentenced to an aggregate prison term of 104 to 155 years. In his habeas corpus petition, Appellant asserted that the prosecution had committed a Brady violation and that the trial court erred in denying his motion for a new trial. The court of appeals dismissed the petition on the grounds that Appellant had failed to comply with Ohio Rev. Code 2969.25(C) and that the petition failed to state a valid habeas claim. The Supreme Court affirmed, holding that the court of appeals erred in dismissing the petition for failure to comply with section 2969.25(C) but was correct to dismiss the petition for failure to state a valid habeas claim. View "Davis v. Hill" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus or procedendo, holding that Appellant was not entitled to the writ.In 1992, Appellant was convicted of aggravated murder and sentenced to life imprisonment. In 2021, Appellant filed an action for writs of prohibition and mandamus seeking to have his sentence declared void because Judge Thomas Nurre erroneously imposed costs and fines. The court of appeals granted the motion to dismiss filed by the common pleas court and clerk. The Supreme Court affirmed, holding that this case fell within the general rule that a mandamus action is not an appropriate vehicle for challenging sentencing errors. View "State ex rel. Harris v. Hamilton County Clerk of Courts" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus ordering the Cuyahoga County Clerk of Courts to produce various records relating to criminal proceedings against Parker Bey in the Cuyahoga County Court of Common Pleas, holding that Bey was not entitled to relief.Twice, the court of appeals denied Bey a writ of mandamus. After the first denial of the writ, the Supreme Court held that the court of appeals erred in applying the Ohio Rules of Superintendence as a basis for denying mandamus relief and remanded for a determination as to whether Bey was entitled to relief under the Public Records Act, Ohio Rev. Code 149.43. On remand, the court of appeals again denied the writ. The Supreme Court affirmed, holding that the court of appeals did not err in denying the writ. View "State ex rel. Bey v. Byrd" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court issuing a new sentencing entry that included a required notification as to the postrelease-control portion of Defendant's sentence, holding that holding that the trial court's new sentencing entry was improper.In 2008, Defendant was sentenced to a nine-year prison term for his convictions of kidnapping, rape, and robbery. The trial court failed to include in Defendant's sentencing entry a statement that postrelease control was mandatory. In 2018, the trial court issued a new sentencing entry that included a notification that postrelease control was mandatory and that a violation of postrelease control would subject Defendant to the consequences set forth in Ohio Rev. Code 2967.28. The court of appeals affirmed. The Supreme Court vacated the portion of the 2018 sentencing entry imposing postrelease control, holding (1) res judicata precluded the State's collateral attack on Defendant's sentence; and (2) therefore, the trial court's sentencing entry was improper and of no effect. View "State v. Bates" on Justia Law