Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus against Appellee, the former warden of the correctional institution at which Appellant was an inmate, holding that there was no error.Appellant was convicted of four counts of complicity to commit rape and was sentenced to four consecutive terms of life imprisonment. Many years later, Appellant filed against the warden a complaint for a writ of habeas corpus alleging that he was not informed of his right to appeal. The court of appeals dismissed the action. The Supreme Court affirmed, holding that the court of appeals correctly dismissed Appellant's complaint for a writ of habeas corpus. View "Dunkle v. Hill" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that the Retroactivity Clause of the Ohio Constitution prohibits the state from applying "Sierah's Law," Ohio Rev. Code 2903.41 through 2903.44, to an offender whose criminal conduct occurred prior to the legislation's effective date, holding that this Court's determination in State v. Hubbard, __ N.E.3d __ (Ohio 2021), was dispositive of this case.Sierah's Law, which created a violent offender database, became effective March 20, 2019. Appellant in this case pleaded guilty on March 4, 2019 to several crimes. At a sentencing hearing on April 1, 2019, Appellant was notified of his duty to register as a violent offender. The court of appeals reversed, concluding that the Retroactivity Clause prohibited the state from applying Sierah's Law to Appellant. The Supreme Court reversed, holding that, adhering to this Court's determination in Hubbard, the application of Sierah's Law to conduct that occurred prior to its effective date does not violate the Retroactivity Clause of Ohio Const. art. II, 28. View "State v. Jarvis" on Justia Law

The Supreme Court held that the application of "Sierah's Law," Ohio Rev. Code 2903.41 through 2903.44, to conduct that occurred prior to its effective date, does not violate the Retroactivity Clause of Ohio Const. art. II, 28.Seirah's Law presumptively requires offenders who are convicted of certain crimes to enroll in Ohio's "Violent Offender Database" for a period of ten years and presumptively requires an offender to enroll if he was convicted of any of those offenses or was serving a termination of confinement for the offense on or after the provisions' effective date. The court of appeals in this case determined that Sierah's Law does not affect a substantive right because it does not "impose a new burden in the constitutional sense" and therefore may be applied to conduct that occurred prior to its effective date. The Supreme Court affirmed, holding that the application of Sierah's Law to violent offenders who committed their offenses prior to its effective date does not violate the Retroactivity Clause of the Ohio Constitution. View "State v. Hubbard" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition requesting a writ of mandamus to compel the Cuyahoga County Court of Common Pleas to vacate journal entries that modified Appellant's original sentencing entries in two criminal cases, holding that the court of appeals did not err.In 1978, Appellant was convicted, in two separate cases, of numerous crimes. In 2021, Appellant filed a petition for a writ of mandamus alleging that the common pleas court patently and unambiguously lacked jurisdiction to modify his sentences while his convictions were being challenged on appeal. Specifically, Appellant alleged that after he had filed his notices of appeals of his convictions the common pleas court filed journal entires stating that his sentencing entries were modified in part. The court of appeals dismissed the petition and found Appellant to be a vexatious litigator. The Supreme Court affirmed, holding that the court of appeals (1) correctly dismissed Appellant's petition because he did not allege facts showing that the relief he sought would benefit him; and (2) did not err in finding Appellant to be a vexatious litigator. View "State ex rel. Newell v. Cuyahoga County Court of Common Pleas" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming the judgment of the trial court dismissing Plaintiffs' complaint seeking an injunction halting their execution and a declaration that the Department of Rehabilitation and Correction's (DRC) written execution protocol was invalid, holding that there was no error.Plaintiffs were two condemned inmates who challenged the DRC's written execution protocol setting forth the specific process by which DRC personnel are to carry out death sentences by lethal injection. Specifically, Plaintiffs argued (1) DRC may adopt the execution protocol only by following the procedures for promulgating it as an administrative rule, in accordance with Ohio Rev. Code 111.15(B); and (2) until these procedures were followed, the protocol was invalid and could not be used to carry out death sentences. The trial court granted summary judgment for the State, and the court of appeals affirmed. The Supreme Court affirmed, holding (1) the execution protocol was neither a rule having a general and uniform application nor an internal management rule; and (2) therefore, the protocol was not subject to the rule-making requirements of Ohio Rev. Code 111.15. View "O'Neal v. State" on Justia Law

The Supreme Court denied Relator's request seeking a writ of mandamus ordering the public-records officer for the Ohio Adult Parole Authority (APA) to produce records that Relator claimed to have requested under Ohio's Public Records Act, Ohio Rev. Code 149.43, holding that Relator was not entitled to the writ.In his mandamus action, Relator alleged that he sent a public-records request to the APA's public-records officer seeking public records from the personnel files of six Ohio Parole Board members who were members of the panel for Relator's parole hearing and that the officer had not responded to his request. The Supreme Court denied mandamus relief, holding that because Relator failed to provide evidence to demonstrate that he delivered the alleged public-records request to the APA at all, Relator was not entitled to relief in mandamus. View "State ex rel. Griffin v. Doe" on Justia Law

The Supreme Court denied the writ of mandamus sought by Relator, an inmate at the Toledo Correctional Institution (TCI), to compel Respondent, the public-records custodian, to provide the names of five inmates who were allegedly murdered at TCI between 2012 and 2014, holding that Relator failed to show that he had requested an existing record.Relator filed this original action seeking a writ of mandamus to compel Respondent to produce records in response to requests, alleging that a policy required the creation of incident reports concerning any murders that occur within a prison. The Supreme Court denied the writ, holding that Relator was not entitled to relief because requests that require the records custodian to create a new record by searching for selected information are improper requests under Ohio Rev. Code 149.43. View "State ex rel. Griffin v. Sehlmeyer" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition to vacate his murder conviction, holding that the court of appeals was correct to dismiss Appellant's claim.Appellant was convicted of murder in 2014. In 2020, Appellant filed a complaint for writs of mandamus and prohibition in the court of appeals against Judge Daniel Hogan, the now-retired judge who presided over his criminal case, alleging that his conviction must be vacated because Judge Hogan committed "fraud." The court of appeals dismissed the complaint. The Supreme Court affirmed, holding (1) the court of appeals correctly dismissed Appellant's complaint; and (2) Appellant's motion for judicial notice is denied. View "State ex rel. Jones v. Hogan" on Justia Law

The Supreme Court affirmed Defendant's sentences of death imposed in connection with his convictions of four counts of aggravated murder with multiple death specifications as to each count, holding that each of Defendant's four death sentences were appropriate and proportionate.After a trial, Defendant was found guilty of four counts of aggravated robbery and other crimes. Defendant was sentenced to death on all four counts of aggravated murder. The Supreme Court affirmed, holding (1) the trial court did not deny Defendant due process by not ordering a competency hearing sua sponte; (2) Defendant's claims that both his jury waiver and his subsequent guilty pleas were invalid because they were not knowing, voluntary, and intelligent were unavailing; (3) Defendant's trial court rendered constitutionally effective assistance; and (4) in sentencing Defendant, the court did not improperly weigh nonstatutory aggravating circumstances against him or improperly discount the mitigating factors. View "State v. Lawson" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's complaint seeking a writ of mandamus to compel the Cuyahoga County Court of Common Pleas to rule on Appellant's motion to reinstate bail and to set bail terms, holding that there was no error.Appellant was being held in the Cuyahoga County jail where he awaited trial on criminal charges in two cases. In Appellant's first criminal case, the trial court set bail at $5,000. Appellant posted ten percent of that amount and was released. In Appellant's second criminal case, the trial court set bail in the amount of $100,000 and revoked Appellant's bail in the first case based on his failure to appeal at a pretrial hearing. Appellant sought to have his bail reinstated, but the trial court denied relief. Appellant then filed a complaint for a writ of mandamus asking the court of appeals to issue an order compelling the trial court to rule on his motions and to set bail conditions that would allow for his pretrial release in his first case. The court of appeals denied relief. The Supreme Court affirmed, holding that Appellant's claim did not lie in mandamus. View "State ex rel. Wesley v. Cuyahoga County Court of Common Pleas" on Justia Law