Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals upholding Defendant's convictions in a second appeal, holding that Defendant's right to a speedy trial was violated after his case was remanded to the trial court for retrial.The trial court convicted Defendant of two counts of aggravated robbery and one count of failure to comply with an order or signal of a police officer. The court of appeals reversed and remanded the matter. On remand, Defendant pleaded no contest to the charges of having a weapon under disability and failing to comply with an order or signal of a police officer. The court of appeals affirmed, concluding that Defendant's constitutional right to a speedy trial was not violated during the trial court's remand proceedings. The Supreme Court reversed and vacated Defendant's convictions, holding that all four factors under Barker v. Wingo, 407 U.S. 514 (1972) weighed in Defendant's favor. View "State v. Long" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus, holding that the court of appeals did not err.Appellant, an inmate, was serving a sentence of fifteen years to life for the murder of Ray Emerson. In 2012, Appellant received a copy of the coroner's complete report on the autopsy on the body of Ray. In 2014, Appellant requested photographs of Ray's injuries. The office of the medical examiner did not provide the photographs. In 2019, Appellant filed a petition requesting a writ of mandamus to compel the office to provide photographs of Ray's stab wounds, X-rays of the stab wounds, Ray's death certificate, and a signed autopsy report. The court of appeals granted the office's motion to dismiss. The Supreme Court affirmed, holding that the court of appeals was correct to deny Appellant's request for a writ of mandamus. View "State ex rel. Bandy v. Gilson" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing the trial court's judgment ordering Michael Knab to make restitution to the City of Centerville, holding that a municipality is not a victim and has no right to restitution under Ohio Const. Art I, 10a, a provision known as Marsy's law.Knab was found guilty of making a false report to law enforcement and improper use of the 9-1-1 emergency system. The trial court ordered Knab to pay restitution to Centerville for the costs it had incurred responding to Knab's 9-1-1 call. The court of appeals affirmed Defendant's convictions but vacated the restitution order, holding that Centerville was not a victim for purposes of restitution when it was carrying out its official duties. The Supreme Court affirmed, holding that a municipal corporation does not qualify as a victim under Marsy's Law and is not entitled to restitution under that provision. View "Centerville v. Knab" on Justia Law

The Supreme Court affirmed the decision of the court of appeals reversing Defendant's sentence of twenty-five years to life in prison for rape based on the trial court's finding that Defendant had compelled the victim to submit by force, holding that the Sixth Amendment requires that such a finding be made by a jury.Defendant was convicted of rape of a child under the age of thirteen. At a second resentencing, the trial court sentenced Defendant to twenty-five years to life under Ohio Rev. Code 2971.03(B)(1)(c). The court of appeals reversed, holding that Defendant's sentence was not authorized because none of the prerequisites for such a sentence under Ohio Rev. Code 2971.03(B)(1)(c) was present and that permitting a trial court to make a finding of force for the purpose of imposing a sentence under the statute would violate the Sixth Amendment based on Alleyne v. United States, 570 U.S. 99 (2013). The Supreme Court affirmed, holding that Alleyne requires that a finding that the victim was compelled to submit by force or that one of the other factors under subsection (B)(1)(c) is present be made by a jury. View "State v. Bowers" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's request for a writ of mandamus against Governor Mike DeWine, holding that Appellant failed to establish by clear and convincing evidence a clear legal right to the requested relief and a clear legal duty on the part of the Governor to provide it.Appellant, an inmate, sent a public-records request to the Governor requesting certain documents. Appellant later filed this action seeking a writ of mandamus to compel the production of the documents. The court of appeals denied the writ of mandamus. The Supreme Court affirmed, holding that where the evidence showed that the Govenor's office satisfied its duty to make the records available by sending them to the correctional institution at which Appellant was an inmate, Appellant was not entitled to his requested relief. View "State ex rel. Ware v. DeWine" on Justia Law

The Supreme Court denied the writ of mandamus sought by Relator, an inmate at the Toledo Correction Institution, ordering the production of shift rosters that show the duty assignments of correctional officers within the prison, holding that the shift rosters are security records exempt from disclosure under the Public Records Act.Respondent, the public-records custodian at TCI, withheld the requested records from Relator on the basis that they were "security records" exempt from public-records disclosure under Ohio Rev. Code 149.433(A) and (B). Relator then filed this action seeking a writ of mandamus ordering Respondent to produce the requested records. The Supreme Court denied the writ, holding that the shift rosters are security records exempt from public records disclosure under section 149.433(A) and (B). View "State ex rel. Burfitt v. Sehlmeyer" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus against Ashland County Court of Common Pleas Judge Ronald Forsthoefel, holding that the court of appeals correctly found that Appellant's complaint failed to state a claim for relief in mandamus.Appellant was found guilty of six drug-related counts, and Judge Forsthoefel sentenced him to an aggregate term of sixty-one months. Appellant later filed a petition seeking a writ of mandamus to compel Judge Forsthoefel to vacate his sentence, merge counts four and five, and resentence him. The court of appeals granted Judge Forsthoefel's motion to dismiss. The Supreme Court affirmed, holding that Appellant had an adequate remedy by way of appeal. View "State ex rel. Olmstead v. Forsthoefel" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's sentence for violating the conditions of his community control, holding that the trial court was within its authority to impose Defendant's full suspended twelve-month prison sentence under the circumstances of this case.As a condition of his community-control sanction Defendant was ordered to complete a drug treatment program. Soon after entering the program, Defendant was kicked out for misconduct. Defendant's probation officer filed a complaint alleging that Defendant had violated the conditions of his community control. Defendant admitted to the alleged violations. The trial court imposed the twelve-month prison term. Defendant appealed, arguing that his failure to complete the programs were technical violations, and therefore, his sentence could not exceed the ninety-day sentencing cap contained in Ohio Rev. Code 2929.15(B)(1)(c)(i). The Supreme Court affirmed, holding (1) the circumstances surrounding Defendant's violations were such that they could not be deemed merely technical in nature; and (2) therefore, the sentencing cap did not apply, and the trial court had discretion to sentence Defendant to a twelve-month prison term. View "State v. Castner" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions for corrupting another with drugs and other offenses but remanding the matter to the trial court for resentencing because the trial court had erred in failing to merge the two convictions for corrupting another with drugs as allied offenses of similar import, holding that the trial court properly instructed the jury on the causation element of the offense of corrupting another with drugs.On appeal, Defendant argued that, when instructing a jury on the causation element of the offense of corrupting another with drugs, the trial court is required to inform the jury that it must find not only that the accused's conduct was the but-for cause of serious physical harm to the victim but also that it was an independently sufficient cause of that harm. The Supreme Court affirmed, holding that because Defendant did not ask the trial court to give that instruction, the propriety of such an instruction was not before the Court in this case. View "State v. Price" on Justia Law

The Supreme Court affirmed the judgment of the Fourth District Court of Appeals dismissing Appellant's complaint for a writ of procedendo against Judge Mark Kuhn of the Scioto County Court of Common Pleas, holding that the dismissal of Appellant's complaint was appropriate under the circumstances.Appellant, an inmate, filed a complaint for a writ of procedendo seeking an order compelling Judge Kuhn to journalize a final judgment of conviction. The Fourth District dismissed Appellant's complaint for lack of jurisdiction. The Supreme Court affirmed on different grounds, holding that the dismissal of Appellant's petition was appropriate because Appellant failed to show a clear legal right to relief in procedendo. View "McDougald v. Kuhn" on Justia Law