Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals upholding the order of the municipal court granting Defendant's motion to suppress, holding that the police officer's investigatory stop of Defendant was reasonable and thus did not violate the Fourth Amendment.At issue was whether the officer had reasonable suspicion to briefly detain Defendant in order to confirm or dispel an unidentified witness's claim that Defendant was operating a motor vehicle while intoxicated. The trial court granted Defendant's motion to suppress. The court of appeals affirmed, holding that the officer lacked the reasonable suspicion necessary to effectuate a lawful investigatory stop because the anonymous tip lacked sufficient indicia of reliability and because there was no evidence of erratic driving by Defendant prior to the stop. The Supreme Court reversed, holding that the officer had reasonable suspicion to investigate whether Defendant was driving while drunk based on the unidentified customer's tip and the officer's own partial corroboration of that tip. View "State v. Tidwell" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying writs of mandamus to compel appellees - the Cuyahoga County Prosecutor's Office and the City of North Olmsted - to prosecute crimes allegedly committed by Appellant's parents when Appellant was a minor, holding that the court of appeals did not err in denying Appellant's requested relief in mandamus.When Appellant was twenty-five years old, Appellant filed two charging affidavits alleging that his father committed felonious assault and felony domestic abuse and that his mother committed felony child endangering when Appellant was a minor. The prosecutor declined to prosecute or issue an arrest warrant. Appellant then commenced this action. The court of appeals granted the prosecutor's motion for summary judgment and denied the requested writ of mandamus. The Supreme Court affirmed, holding that the court of appeals did not err in denying Appellant's requested relief in mandamus. View "State ex rel. A.N. v. Cuyahoga County Prosecutor's Office" on Justia Law

The Supreme Court granted in part and denied in part the application of Charles Summers for court costs, attorney fees, and statutory damages following the Court's grant of a writ of mandamus ordering Respondents to produce documents to Summers, holding that Summers was entitled to an award of court costs.This case concerned Summers's request for public records relating to his son's criminal case. Summers sent the requests to Respondents - Mercer County Prosecuting Attorney Matthew Fox and Mercer County Sheriff Jeff Grey. When court-ordered mediation resulted in Summers receiving some, but not all, of the documents that he had requested the Supreme Court granted his writ of mandamus in part and denied it in part. Summers then filed his petition for an award of court costs, statutory damages, and attorney fees. The Supreme Court held (1) Summers was entitled to court costs; (2) Summers's status as the prevailing party in his mandamus action did not entitle him to an award of attorney fees, nor was he entitled to an award of bad-faith attorney fees; and (3) Summers was not entitled to an award of statutory damages. View "State ex rel. Summers v. Fox" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's habeas corpus petition and denied all of Appellant's motions seeking various orders on appeal, holding that Appellant was not entitled to relief.Appellant was convicted of aggravated murder and other crimes and sentenced to life imprisonment without the possibility of parole. Appellant later filed a petition for a writ of habeas corpus alleging that the trial court committed numerous due process violations during his trial. The court of appeals dismissed the action. The Supreme Court affirmed and denied Appellant's motions, holding (1) Appellant's arguments did not state claims cognizable in habeas corpus; and (2) Appellant's motions were improper. View "Orr v. Schweitzer" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's habeas corpus complaint and, in a separate case, the court of appeals' order denying Appellant's motion to vacate the assessment of court costs against him, holding that the court of appeals did not err.Appellant, an inmate, filed a complaint for a writ of habeas corpus alleging that his original sentence was partially void due to an improper inclusion of a postrelease control sanction. The court of appeals dismissed the complaint, finding that Appellant failed to state any cognizable claim for relief in habeas corpus. After Appellant was sent notice of the court's judgment against him for the payment of court costs Appellant filed a document that the court of appeals treated as a motion to vacate court costs. The court of appeals denied the motion. The Supreme Court affirmed, holding (1) Appellant's claims were not cognizable in habeas corpus; and (2) the court of appeals properly denied Appellant's motion to vacate the judgment of court costs assessed against him. View "State ex rel. Davis v. Turner" on Justia Law

In this second public-records action filed by Relators, Hogan Lovells U.S., LLP and Elizabeth Och, against Respondent, the Ohio Department of Rehabilitation and Correction (DRC), the Supreme Court denied Relators' request for a writ of mandamus requesting DRC's records relating to lethal injections, holding that Relators were not entitled to a writ of mandamus.In the first public-records case filed by Relators, the Supreme Court granted Relators' request for a writ of mandamus in part and ordered DRC to provide certain records relating to DRC's supply of drugs for its use in lethal injections. Although DRC provided more than 120 pages of documents, it asserted that two other documents at issue in this case were exempt from disclosure. Relators then brought this action seeking the withheld documents. The Supreme Court denied relief, holding that Relators were not entitled to a writ of mandamus concerning the requests but that, because DRC failed to timely respond to the request, Relators were entitled to an award of statutory damages in the amount of $500. View "State ex rel. Hogan Lovells U.S., LLP v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court held that Defendant, who pleaded no contest in 1987 to attempted murder after shooting a young man in the neck and was reindicted in 2016 for the aggravated murder of the same man after he died allegedly as a result of injuries from the shooting, may be prosecuted on the new murder charge.In 1987, Defendant pled no contest to attempted murder after shooting Danuell Jackson in the neck, leaving him paralyzed from the waist down. In 2014, Jackson died. The autospy examiner ruled the death a homicide because it was caused by infections attributed to Jackson's paraplegia. In 2016, the State indicted Defendant for the aggravated murder of Jackson. Defendant moved to dismiss the indictment, arguing that it violated the terms of a negotiated plea agreement Defendant claimed he entered into with the State in 1987. The State countered that there had not been a negotiated plea. The trial court granted Defendant's motion to dismiss. The court of appeals affirmed. The Supreme Court reversed, holding that because there was no evidence that Defendant's 1987 plea was the product of negotiations between the State and Defendant, the rule announced in State v. Carpenter, 623 N.E.2d 66 (Ohio 1993), did not prevent the State from prosecuting Defendant on the new murder charge. View "State v. Azeen" 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 officials to transfer him from the Northeast Ohio Correctional Center (NEOCC) to the Franklin County jail, holding that the court of appeals did not err.The court of appeals dismissed Appellant's complaint in its entirety as moot, concluding that any transfer of Appellant from NEOCC to the Franklin County jail would have been a vain act. The Supreme Court affirmed, holding that granting the writ of mandamus Appellant sought to compel his transfer would do nothing more than require a vain act. View "State ex rel. Peoples v. O'Shaughnessy" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus compelling Summit County Common Pleas Court Judge Alison McCarty to vacate his conviction and resentence him, holding that the court of appeals correctly dismissed Appellant's complaint.Appellant was convicted of multiple felony charges, including rape, felonious assault, and kidnapping. With respect to the kidnapping charge, the jury did not specify whether Appellant had violated Ohio Rev. Code 2905.01(A)(3), (A)(4), or both. Appellant subsequently filed a complaint for writ of mandamus alleging, among other things, that the jury failed to render a unanimous verdict. The court of appeals dismissed the complaint for failure to state a claim. The Supreme Court affirmed, holding that Appellant had an adequate remedy to challenge the alleged error in his direct appeal. View "State ex rel. Person v. McCarty" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against Lake County Common Pleas Court Judge Vincent A. Culotta, holding that the mandamus complaint was properly dismissed.Appellant was convicted of conspiracy to commit aggravated murder and other felonies. After he was sentenced, Appellant filed a motion to correct his award of jail-time credit. Unhappy with the award, the judge awarded upon granting the motion, Appellant unsuccessfully appealed. Appellant then brought a mandamus complaint seeking to compel Judge Culotta to conduct a new sentencing hearing and to correct his jail-time-credit award. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that the complaint did not state a cognizable mandamus claim. View "State ex rel. Sands v. Culotta" on Justia Law