Justia Criminal Law Opinion Summaries

The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction for possession of cocaine, holding the State did not prove beyond a reasonable doubt that Appellant committed the offense of possession of cocaine or any element of that offense within Seneca County.After Defendant gave birth to her son, J.B., he was tested for illegal substances and the test results showed the presence of cocaine metabolites in his urine and meconium. After a bench trial in the Seneca County Court of Common Pleas, Defendant was convicted of one count of possession of cocaine. The Supreme Court vacated Defendant's conviction of possession of cocaine, holding that the State failed to meet its burden of proving beyond a reasonable doubt that Defendant committed the offense in Seneca County. View "State v. Foreman" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Defendant's appeal of an order requiring his attorney to provide information to the prosecution about what Defendant's alibi witnesses intended to say at trial, holding that this Court lacked jurisdiction.Defendant, a high school teacher, was indicted on allegations that he had engaged in sexual conduct with one of his students. The State filed a motion to compel discovery, requesting information summarizing proposed testimony of defense witnesses, particularly the testimony of Defendant's ex-girlfriend, one of his alibi witnesses. The trial court issued an order granting the State's motion to compel. Defendant appealed the trial court's discovery order. The court of appeals granted the State's motion to dismiss, concluding that the order was not final and appealable. The Supreme Court affirmed, holding that the order at issue did not satisfy the requirements of Ohio Rev. Code 2505.02(B)(4) for being a final order. View "State v. Glenn" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's complaint seeking a writ of mandamus to compel the Hamilton County Coroner to produce a DNA record, holding that the court of appeals correctly dismissed the mandamus claim.Appellant sent several pieces of correpondence to the coroner's office asking for DNA records related to his criminal case. After the coroner responded, Appellant filed this complaint in the court of appeals seeking a writ of mandamus to compel the coroner to release for inspection all DNA records that had been created for and preserved in the CODIS database. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that the evidence did not show that the coroner had any records responsive to Appellant's requests. View "State ex rel. Long v. Hamilton County Coroner" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's aggravated murder conviction and discharging him from further prosecution for that crime, holding that the court of appeals erred.Defendant was convicted by a jury of aggravated murder, in violation of Ohio Rev. Code 2903.01(A). The court of appeals reversed, concluding that the evidence was insufficient to show that Defendant acted with prior calculation and design. The Supreme Court reversed, holding (1) in reviewing whether evidence is sufficient to establish the prior-calculation-and-design element of the crime of aggravated murder, a court must consider whether the evidence supports a finding that the defendant acted with advance reasoning and purpose to kill; (2) the court of appeals failed properly to apply this standard and inappropriately conducted its own weighing of the evidence; and (3) a reasonable juror could properly find that Defendant acted with prior calculation and design. View "State v. Jones" on Justia Law

The Supreme Court denied Appellant's petition seeking a writ of habeas corpus against the warden of the Lorain Correctional Institution, holding that Appellant failed to show that he was entitled to the writ.Appellant, an inmate, filed this petition seeking a writ of habeas corpus, arguing that the way his revocation hearing was conducted violated his due process rights. Specifically, Appellant argued that because of a delay in conducting a "proper" hearing in his case, he was prejudiced. The Supreme Court denied the writ, holding that Appellant failed to demonstrate that he was entitled to a writ of habeas corpus. View "State ex rel. Ellison v. Black" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's habeas corpus complaint against Kenneth Black, the warden of the Richland Correctional Institution, where Appellant was incarcerated, for failure to comply with Ohio Rev. Code 2969.25(A) and failure to state a cognizable claim for relief in habeas corpus, holding that there was no error.Defendant was convicted of abduction and domestic violence and sentenced to consecutive prison terms. The appellate court affirmed. This appeal concerned Defendant's complaint for a writ of habeas corpus in which Defendant alleged that his domestic violence conviction was void and that he was entitled to immediate release. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that Defendant's habeas complaint failed to state a valid claim for relief. View "DeVore v. Black" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of one count of drug trafficking, a first-degree felony with a forfeiture specification, and one count of drug possession and trafficking, holding the trial court did not have an affirmative duty to inquiry about a possible conflict of interest.At issue on appeal was whether a trial court has an affirmative duty to inquire into the possible conflict of interest created by an attorney's dual or multiple representation of codefendants in a criminal case. The Supreme Court answered the question in the negative, holding (1) when a trial court does not know, and should not reasonably have known, of a possible conflict of interest in an attorney's representation of two or more codefendants charged with a crime, the trial court has no affirmative duty to inquire whether a conflict of interest exists; and (2) there was nothing in the record here giving rise to an affirmative duty on the part of the trial court to inquire about a potential conflict of interest resulting from the dual representation of Defendant and his codefendant. View "State v. Williams" on Justia Law

The Supreme Court vacated Defendant's convictions of murder with capital specifications, aggravated burglary, kidnapping, and abuse of a corpse, holding that because the trial court accepted Defendant's guilty plea without first strictly complying with Crim.R. 11(C)(2)(c), Defendant's guilty plea was invalid.Specifically, the Supreme Court held that the trial court failed strictly to comply with the requirements for a valid plea colloquy under Crim.R. 11(C)(2)(c), and neither the prosecutor nor defense counsel brought the omitted constitutional rights to the court's attention at the time of the initial plea colloquy. Because this inattention was impermissible, especially in a case where a potential death sentence was at issue, the Supreme Court vacated Defendant's convictions and sentences and remanded the cause to the common pleas court for new proceedings. View "State v. Brinkman" on Justia Law

The Supreme Court affirmed Defendant's convictions of aggravated murder with an escaping-detection specification, kidnapping, felonious assault, possessing criminal tools, tampering with evidence, and having weapons while under a disability and Defendant's sentence of death, holding that there was no error in proceedings below.Specifically, the Supreme Court held (1) the State proved beyond a reasonable doubt that Defendant committed the offenses of aggravated murder and kidnapping; (2) the trial court did not deny Defendant's right to a fair trial by denying his motion for a new venire; (3) trial counsel did not provide ineffective assistance; (4) the trial court did not err in admitting evidence of other crimes, wrongs, or acts; (5) there was no error in the sentencing opinion; and (6) there was no other error in Defendant's sentencing. View "State v. Worley" 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 Keith Foley, warden of the Grafton Correctional Institution, holding that the information was insufficient to satisfy Ohio Rev. Code 2969.25(A).Appellant was indicted in two separate indictments on multiple counts of kidnapping and gross sexual imposition. The court dismissed the first indictment, after which Appellant pleaded guilty to five counts of gross sexual imposition. Appellant later filed a petition for a writ of habeas corpus alleging that the State was required to seek a new indictment before Appellant could be tried. The court of appeals dismissed the action because Def Appellant endant had failed to attach a proper affidavit describing his prior civil actions, as required by section 2969.25(A). The Supreme Court affirmed, holding that Appellant's failure to identify certain information in his affidavit required dismissal of his complaint. View "State ex rel. Steele v. Foley" on Justia Law