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 against Warden Lyneal Wainwright, holding that Appellant was not entitled to immediate release.Between 1992 and 2007 Appellant was paroled four times. In 2008, Appellant was convicted of several offenses and sentenced. In his petition for writ of habeas corpus Appellant alleged that the 2008 sentencing court did not order him to serve his firearm-specification sentences consecutively to his two prior robbery sentences and that he should have been released on December 13, 2019. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that because Appellant was not complete his lawfully imposed sentences until 2025 he was not entitled to immediate release. View "State ex rel. Hunley v. Wainwright" 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 correctly dismissed the habeas petition for failure to comply with Ohio Rev. Code 2969.25(A).Appellant pleaded guilty to four counts of trafficking in cocaine and one count or engaging in a pattern of corrupt activity. The trial court sentenced Appellant to an aggregate prison sentence of fourteen years. Appellant later filed his habeas petition alleging that his sentences were void because the trial court failed to make the findings required under Ohio Rev. Code 2929.14(C)(4) before imposing consecutive prison sentences. The Supreme Court affirmed, holding that the petition was properly dismissed. View "State ex rel. Sanchez v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus seeking to compel the Lake County Clerk of Courts to provide him with a record related to his criminal case, holding that the court of appeals correctly dismissed the complaint for failure to comply with Ohio Rev. Code 2929.25(A).In affirming the judgment, the Supreme Court noted that it was undisputed that Appellant was an inmate and that the Clerk of Courts was a government employee. Therefore, Appellant was required to comply with section 2969.25(A). The Supreme Court held that the court of appeals was correct in finding that Appellant's affidavit failed to provide the information required by section 2969.25(A)(1). View "State ex rel. Sands v. Kelly" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of procedendo and/or mandamus seeking to compel the trial court's compliance with Civ.R. 58(B), holding that, although the court of appeals' judgment dismissing the petition was correct.Appellant, an inmate, sought the writ to compel Hamilton County Court of Common Pleas Judge Steven Martin to serve upon Appellant a judgment entry in which Appellant's motion to correct his sentencing entry was denied. The court of appeals dismissed the motion. The Supreme Court affirmed, holding that granting Appellant his requested writ of mandamus was of no benefit to him because Appellant could still timely file a notice of appeal from the judgment entry. View "State ex rel. Thomas v. Nestor" 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 Prosecuting Attorney Charles Coulson, holding that Appellant was not entitled to the writ.Appellant was convicted of three counts of conspiracy to commit aggravated murder, two counts of conspiracy to commit aggravated arson, and one count of engaging in a pattern of corrupt activity. In his action for a writ of mandamus, Appellant alleged that his convictions were based on perjured testimony and that Coulson had a constitutional duty to provide him a fair trial. The court of appeals granted Coulson's motion to dismiss. The Supreme Court affirmed, holding that the court of appeals correctly dismissed the complaint for failure to state a claim upon which relief can be granted because Coulson was not under a clear legal duty to perform an action that he had no legal authority to undertake. View "State ex rel. Sands v. Coulson" on Justia Law

The Supreme Court affirmed Appellant's petition for a writ of habeas corpus alleging that he was entitled to immediate release from prison because the Bureau of Sentence Computation (BSC) and the Department of Rehabilitation and Correction (DRC) failed to update their records after Appellant was resentenced in 2000, holding that Appellant failed to state a claim upon which relief can be granted.In dismissing the petition, the Third District held that Appellant had failed to attach all applicable commitment papers to his petition, as required under Ohio Rev. Code 2725.04(D), and that Appellant had not alleged facts showing that he was entitled to immediate release from prison. The Supreme Court affirmed, holding (1) Appellant provided his commitment papers with his petition; and (2) Appellant was not entitled to immediate release. View "Farley v. Wainwright" on Justia Law

The Supreme Court reversed the court of appeals' decision reversing Defendant-doctor's convictions on the ground that the trial court should have granted Defendant's motion to suppress incriminating answers he gave during a medical board investigation, holding that the State may use incriminating answers given by a doctor during a medical board investigation in a subsequent criminal prosecution of the doctor.Defendant was convicted of three third-degree misdemeanor counts of sexual imposition. The court of appeals reversed the denial of Defendant's motion to suppress statements he had made to the medical board investigator as having been illegally compelled in violation of the Fifth Amendment. The Supreme Court reversed, holding (1) a medical license is a property right, the threatened loss of which is a form of coercion that can compromise the constitutional privilege against self-incrimination; (2) for coercion to be sufficient to warrant the suppression of statements made during a medical board investigative interview, the person making the statements must subjectively believe that asserting the privilege against self-incrimination could cause the loss of the person's medical license, and that belief must be objectively reasonable; and (3) Defendant's belief that he could lose his medical license if he refused to truthfully answer questions posed by the medical-board investigator was not objectively reasonable. View "State v. Gideon" on Justia Law

In this appeal concerning two prison sentences that Defendant received related to 133.62 grams of powder containing detectable amounts of heroin and fentanyl the Supreme Court held that the sentence violated the double jeopardy protections of the Ohio and United States Constitutions.Defendant was sentenced on a first-degree felony conviction for trafficking in 133.62 grams of heroin and was separately sentenced on a second-degree felony conviction for trafficking in 133.62 grams of fentanyl. The court of appeals upheld the sentences, concluding that the General Assembly intended to separately punish an offender for trafficking in different types of drugs. The Supreme Court reversed, vacated the sentences, and remanded the case for resentencing, holding that the imposition of two punishments for the same, singular quantity of drugs violated Defendant's constitutional double jeopardy protections. View "State v. Pendleton" on Justia Law

The Supreme Court held that the right to bear arms under the Second Amendment to the United States Constitution does not include the right to carry a firearm while intoxicated, and therefore, Ohio Rev. Code 2923.15 is not unconstitutional.Defendant was found guilty of violating section 2923.15(A), which provides that no person under the influence of alcohol or drugs shall carry or use any firearm. The court of appeals affirmed the conviction. On appeal, Defendant argued that section 2923.15 violates the Second Amendment. The Supreme Court affirmed, holding (1) the constitutionality of section 2923.15 should be judged using intermediate scrutiny; and (2) the statute is constitutional under intermediate scrutiny. View "State v. Weber" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus or a writ of prohibition against Judge Stephen McIntosh of the Franklin County Court of Common Pleas, holding that the court of appeals did not err.Appellant was found guilty of all counts in two criminal cases. Judge McIntosh sentenced Defendant. Appellant then filed an original action seeking a writ of mandamus or a writ of prohibition against Judge McIntosh alleging that the judge had improperly sentenced him. The court of appeals concluded that mandamus was not available because Appellant could have challenged his convictions in a direct appeal. The Supreme Court affirmed, holding that because Appellant's sentencing entry was voidable, mandamus will not lie. View "State ex rel. Romine v. McIntosh" on Justia Law