Justia Criminal Law Opinion Summaries

The Supreme Court granted in part and denied in part a writ of mandamus sought by Charles Summers to compel the production of public records by Mercer County Prosecuting Attorney Matthew Fox and Mercer County Sheriff Jeff Grey, holding that Summers was entitled to a writ of mandamus as to certain requests.Summers pleaded guilty to several counts of sexual battery in violation of Ohio Rev. Code 2907.03. In his public-records request to Mercer County Prosecutor's Office Summers requested several items relating to his criminal prosecution. Summers then requested from the Mercer County Sheriff several other items related to his criminal case. The county denied Summers's requests. Summers then commenced this action. The Supreme Court granted a writ in part, holding that Summers demonstrated by clear and convincing evidence that he had a clear legal right to some of the requested relief, and the county had a clear legal duty to provide that relief. View "State ex rel. Summers v. Fox" on Justia Law

The Supreme Court affirmed Defendant's two aggravated murder convictions and death sentences, holding that no reversible error occurred in the proceedings below.Specifically, the Supreme Court held (1) defense counsel were not ineffective for failing to request a change of venue or in filing a joint motion for a gag order; (2) defense counsel were not ineffective for withdrawing Defendant's plea of not guilty by reason of insanity in Defendant's absence or in failing to request a continuance to obtain additional neuroimaging; (3) defense counsel were deficient for failing to object to certain evidence, but the deficient performance did not result in prejudice; (4) defense counsel made an inappropriate comment during mitigation-phase closing argument, but the comment did not prejudice Defendant; (5) Defendant's remaining ineffective assistance of counsel claims were without merit; (6) the trial court did not err in replacing one juror with an alternate juror; and (7) Defendant's sentences were not unlawful. View "State v. Grate" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that a child-abuse investigator employed by a county children-services agency need not give the warnings required by Miranda v. Arizona, 384 U.S. 436 (1966), before questioning a child suspected of committing child abuse, holding that the questioning in this case violated neither Miranda nor the suspect's federal due process rights.The trial court in this case granted the suspect's motion to suppress, finding that the suspect's statement to the agency had been obtained in violation of his due process rights. The court of appeals reversed. The Supreme Court affirmed, holding that where the evidence demonstrated that the child-abuse investigator who interviewed the suspect was neither a law enforcement officer nor acting under the direction or control of the police and where the suspect's confession was not causally related to any conduct of the police, the court of appeals correctly concluded that the confession resulting from the questioning was admissible at trial. View "In re M.H." on Justia Law

The Supreme Court affirmed the order of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that Appellant failed to state a claim cognizable in habeas corpus.Appellant, an inmate at the Trumbull Correctional Institution, filed a petition for a writ of habeas corpus alleging that his transfer from juvenile court to adult court was void and that, therefore, his resulting convictions were also void. The court of appeals held that Appellant's conviction was barred by res judicata. Further, the court rejected Appellant's claim on the merits. The Supreme Court affirmed, holding that, based on this Court's decision in Smith v. May, 148 N.E.3d 542, Appellant failed to state a claim cognizable in habeas corpus. View "Steele v. Harris" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting the motion filed by Cuyahoga County Court of Common Pleas judge William T. McGinty to dismiss Appellants' action seeking a writ of prohibition to prevent McGinty from enforcing a discovery order, holding that a writ of prohibition was not the correct mechanism to challenge Judge McGinty's order.Kaylynn Counts, who allegedly assaulted Appellants, was awaiting trial before Judge McGinty when she filed a motion requesting an order allowing her to inspect and photograph Appellants' home to aid in "forensically recreating the incident" for her case. Judge McGinty granted the motion. Appellants then filed this action, arguing that Marsy's Law and the Fourth Amendment deprived Judge McGinty of the authority to issue the order permitting Counts and the defense team to have access to Appellants' residence. The court of appeals dismissed the prohibition action. The Supreme Court affirmed, holding that while crime victims have a right under the Ohio Constitution to judicial review of discovery orders affecting their Marcy's Law rights, a writ of prohibition was not the appropriate remedy to challenge Judge McGinty's discovery order, and moreover, Appellants had an adequate remedy in the ordinary course of law by way of an appeal. View "State ex rel. Thomas v. McGinty" on Justia Law

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