Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Ohio
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The Supreme Court granted a writ of mandamus ordering the Ohio Department of Rehabilitation and Correction to produce a copy of a kite that he alleged he had exchanged with the "cashier" of the North Central Correctional Complex (NCCC), where Relator was incarcerated, holding that Relator was entitled to the writ.According to Relator, an NCCC inspector denied Relator's kite request on the ground that she was not responsible for printing kites. After the department denied Relator's grievance Relator brought this mandamus action seeking production of the kite. The Supreme Court granted the writ, holding (1) Relator showed that he had a clear legal right to the requested relief and that the department had a clear legal duty to provide it; and (2) Relator was not entitled to statutory damages. View "State ex rel. Clark v. Ohio Dep't of Rehabilitation & Correction" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals in this criminal case, holding that it does not violate the separation of powers doctrine to tie the judge's ability to reduce the registration period for a person convicted of arson to a recommendation from executive branch officials.In 2012, the General Assembly passed a law codified at Ohio Rev. Code 2909.13(A) establishing a registry of people convicted of arson-related crimes that applied to those convicted of arson or aggravated arson, as well as those convicted of a related attempt or conspiracy or complicity offense. At issue was Ohio Rev. Code 2909.15(D)(2)(b), which provides a limited exception for the lifetime-registration requirement. Defendant in this case pleaded guilty to a single count of arson, for which he was required to register annually for life. At sentencing, challenged the constitutionality of the reduced-registration provision. The trial court denied the challenge, and the court of appeals affirmed. The Supreme Court affirmed, holding that there is no separation of powers violation within Ohio's arson offender registration scheme. View "State v. Daniel" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's writ of habeas corpus arguing that the sentencing court lacked subject-matter jurisdiction over Appellant's case after it issued a final judgment in 2007, holding that the court of appeals did not err.Pursuant to a plea agreement in which Appellant agreed to testify against a potential codefendant, Appellant pleaded guilty to murder with a firearm specification and aggravated robbery. The convictions were vacated based on Appellant's failure to cooperate with prosecutors. After a jury trial, Appellant was convicted of murder aggravated robbery, and aggravated burglary and three-year firearm specifications. On appeal, Appellant argued that the sentencing court lacked subject matter jurisdiction over his case pursuant to State v. Gilbert, 35 N.E.3d 493 (Ohio 2014), after it issued final judgment in 2007. The court of appeals agreed but dismissed the petition because Appellant's 2007 convictions and sentence were still valid and his maximum sentence had not expired. The Supreme Court affirmed, holding that the court of appeals did not err in dismissing the petition because Appellant was not subject to immediate release from prison or confinement. View "Driggins v. Bracy" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals dismissing two complaints Appellant filed seeking writs of mandamus and prohibition, holding that Appellant was not entitled to writs of mandamus or prohibition vacating his convictions and sentence.Appellant filed both a complaint for a writ of mandamus seeking to compel the trial court to vacate his criminal convictions and sentence and a complaint for a writ of prohibition against the trial court raising the same underlying issues. The court of appeals denied the writs, holding (1) Appellant had an adequate remedy in the ordinary course of the law through direct appeal to challenge any violation of his right to counsel; and (2) Appellant was not entitled to a writ requiring the trial court to review issues related to the withdrawal of his counsel on direct appeal. View "State ex rel. Boyd v. Tone" on Justia Law

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The Supreme Court vacated its decision in State v. Gwynne, __ N.E.3d __ (Ohio 2022) (Gwynne IV) and affirmed the judgment of the Fifth District Court of Appeals in this sentencing dispute, holding that the court of appeals properly applied the plain language of Ohio Rev. Code 2953.08(G)(2) in concluding that the record supported the trial court's consecutive sentence findings.Appellant pleaded guilty to seventeen counts of second-degree burglary, among other offenses. The trial court made the findings required under Ohio Rev. Code 2929.14(C)(4) for imposing consecutive sentences and ordered the felony sentences to be served consecutively, for an aggregate sentence of sixty-five years. The appellate court affirmed. The Supreme Court reversed in Gwynne IV, holding on de novo review that the findings required by section 2929.14(C)(4) to impose consecutive prison sentences on an offender must be made in consideration of the aggregate term. The Supreme Court then granted the State's motion for reconsideration, vacated its decision in Gwynne IV and affirmed the court of appeals, holding (1) Ohio Rev. Code 2953.08(G)(2) requires an appellate court to defer to a trial court's consecutive sentence findings, and those findings must be upheld unless they are clearly and convincingly not supported by the record; and (2) the appellate court properly applied that standard. View "State v. Gwynne" on Justia Law

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The Supreme Court denied mandamus relief in this action brought under Ohio's Public Records Act, Ohio Rev. Code 149.43, by Kevin Payne against Kelly Rose, an inspector at the Richland Correctional Institution (RCI), holding that Payne did not have a cognizable claim in mandamus.Payne, an inmate at RCI, sent a public-records request to Rose for a copy of, among other things, JPay support ticket number MACI 1220002928. Rose responded that she obtained the requested record and provided a copy of it to Payne. Payne brought this action seeking a writ of mandamus ordering Rose to produce the requested record and statutory damages. The Supreme Court denied mandamus relief, holding (1) because Payne received his requested record before instituting this action he never had a cognizable claim in mandamus; and (2) statutory damages did not accrue. View "State ex rel. Payne v. Rose" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals reversing Defendant's conviction for violating Ohio Rev. Code 2907.06(A)(2), holding that a jury can reasonably infer that a defendant knew a victim to be substantially impaired so as to convict him of sexual imposition under the statute.Defendant was charged with violating Ohio Rev. Code 2907.06(A)(1) and (2) for his sexual contact with woman who was blind and suffered from unspecified developmental disabilities. The jury found Defendant guilty of both counts of sexual imposition. The court of appeals reversed Defendant's conviction for violating section 2907.06(A)(2), concluding that the victim was not substantially impaired. The Supreme Court reversed, holding (1) knowledge of a victim's "substantial impairment" can be proved both by the defendant's knowledge of the victim's blindness and evidence of the nature of the interactions between the defendant and the developmentally disabled victim; and (2) there was sufficient evidence to find that Defendant knew that the victim's blindness, together with her developmental disabilities, substantially impaired her ability to appraise the nature of and control of Defendant's conduct. View "State v. Jordan" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition ordering the trial court to vacate his criminal sentence, holding that Appellant was not entitled to a writ of mandamus or prohibition.Appellant was convicted of escape, retaliation, and other offenses and sentenced to 26.5 years in prison. Appellant later brought the current action seeking writs of prohibition and mandamus ordering the trial court to vacate his sentencing entries and to grant any other relief to which he was "entitled." The court of appeals dismissed the complaint for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law through direct appeal to raise his claim that the Sixth Amendment requires that a defendant be expressly informed of his right to counsel at each critical stage of the proceeding and that the trial court's failure to do so in his case rendered his sentence void. View "State ex rel. Rarden v. Butler County Common Pleas Court" on Justia Law

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The Supreme Court dismissed Appellant's appeal challenging the decision of the court of appeals denying his motion for leave to continue a mandamus action, holding that Appellant's appeal was prohibited under Ohio Rev. Code 2323.52(G).Appellant filed a complaint for a writ of mandamus alleging that he made a public-records request to Appellee, Franklin County Prosecutor G. Gary Tyack, under Ohio's Public Records Act, Ohio Rev. Code 149.43, for certain documents, and that Tyack had failed to answer his request. Thereafter, in a separate case, Mobley was declared a vexatious litigator. Mobley filed a motion for leave to continue his mandamus action as a vexatious litigator, but the court of appeals denied the motion and dismissed the mandamus action. The Supreme Court dismissed Appellant's appeal, holding that the Court lacked jurisdiction to consider the appeal. View "State ex rel. Mobley v. Tyack" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus arguing that the trial court in which he was convicted lacked subject-matter jurisdiction, holding that the court of appeals correctly dismissed the petition for Appellant's failure to comply with Ohio Rev. Code 2969.25(C).Appellant was convicted on two counts of aggravated murder and sentenced to two concurrent life sentences. Appellant later filed a petition for writ of habeas corpus alleging that the trial court lacked subject matter jurisdiction and failed properly to journalize his sentencing entry. The court of appeals dismissed the petition for Appellant's failure to comply with section 2969.25(C). The Supreme Court affirmed, holding that the petition was properly dismissed due to Appellant's failure to submit a certified statement of his inmate account, as required by section 2969.25(C)(1). View "Grinnell v. Cool" on Justia Law