Justia Criminal Law Opinion Summaries

Articles Posted in Supreme Court of Ohio
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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 correctly dismissed the mandamus petition.Appellant pleaded guilty to one count of rape and was sentenced to life imprisonment with parole eligibility after ten years. The trial court later entered a nunc pro tunc judgment of conviction to specify that Appellant's sentence included five years of mandatory postrelease control. Appellant later commenced this mandamus action arguing that his sentence was void. The court of appeals dismissed the action. The Supreme Court affirmed, holding that Appellant had adequate remedies at law that precluded extraordinary relief in mandamus. View "State ex rel. Crangle v. Summit County Common Pleas Court" 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, holding that the court of appeals properly determined that Appellant's claim was barred by res judicata.Appellant pleaded guilty to involuntary manslaughter and aggravated robbery and was later released on parole. The Ohio Parole Board later found that Appellant had violated the conditions of his release and revoked his parole. Later that year, Appellant filed a petition for writ of habeas corpus, which the common pleas court dismissed. Appellant subsequently filed a second petition for writ of habeas corpus alleging that the Parole Board lacked authority to revoke his parole. The court of appeals dismissed the petition, concluding that the claim was barred under the doctrine of res judicata. The Supreme Court affirmed, holding that the court of appeals did not err. View "Jones v. Wainwright" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals sua sponte dismissing Appellant's complaint seeking a writ of mandamus to compel Lucas County Court of Common Pleas Judge Dean Mandros to grant him judicial release from prison, holding that Appellant failed to state a valid claim for a writ of mandamus.Appellant, an inmate, filed a motion for judicial release under Ohio Rev. Code 2929.20(C)(2). Judge Mandros denied the motion. Appellant subsequently filed this mandamus action seeking a writ of mandamus ordering Judge Mandros to grant judicial release. The court of appeals sua sponte dismissed the complaint. The Supreme Court affirmed, holding that the proper writ for Appellant's purpose was a writ of habeas corpus. View "State ex rel. Neal v. Mandros" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals in this criminal case, holding that Ohio Rev. Code 2913.61(C)(1) unambiguously allows for the aggregation of multiple theft offenses involving one victim into a single count, regardless of the status of the victim.In connection with multiple alleged incidents of passing fraudulent checks at four separate banks, Defendant was convicted of four counts of theft in violation of Ohio Rev. Code 2913.02(A)(3). In accordance with section 2913.61(C)(1), each theft count aggregated the multiple instances of theft alleged against each respective bank. The court of appeals vacated Defendant's sentences in part and otherwise affirmed. In so doing, the court held that section 2913.61(C)(1) does not limit the aggregation of theft offenses under section 2913.02 to offenses involving victims who are disabled adults, elderly persons, or military persons. The Supreme Court affirmed, holding that the unambiguous language of section 2913.61(C)(1) allows aggregation of theft offenses, regardless of the status of the victim. View "State v. Pettus" on Justia Law

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The Supreme Court vacated its earlier judgment granting Relator a writ of mandamus and entered a judgment denying the writ, holding that because a transcript could not be located, the earlier judgment cannot be executed.Relator filed an original action seeking a writ of mandamus to compel Respondent, a former Marion County court reporter, to inform him of the cost to obtain a copy of his 2009 sentencing transcript. The Supreme Court granted the writ. The Court then vacated its judgment, holding that where the only evidence indicating that a transcript of Relator's sentencing hearing existed was the trial court's incorrect statement to that effect, this Court's previous judgment could not be executed. View "State ex rel. Newsome v. Hack" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of mandamus seeking to compel the Ohio Department of Rehabilitation and Correction (DRC) to conduct a hearing concerning an alleged use of force incident, holding that because Appellant did not strictly comply with Ohio Rev. Code 2969.25(A) the court of appeals correctly dismissed his petition.Appellant alleged in his petition that he had suffered injuries when a prison officer used a chemical spray on him while he was incarcerated. The court of appeals granted DRC's motion to dismiss, concluding that Appellant had not satisfied section 2969.25(A). The Supreme Court affirmed, holding that Appellant failed to comply with section 2969.25(A) and that the court of appeals was right to dismiss Appellant's petition. View "State ex rel. Russell v. Ohio Department of Rehabilitation & Correction" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of habeas corpus for failure to state a claim, holding that the court of appeals did not err.Appellant, an inmate, filed a petition for a writ of habeas corpus alleging that the sentencing judge failed to make the findings required by Ohio Rev. Code 2929.14(C) before imposing consecutive sentences. The court of appeals dismissed the petition, concluding that Appellant's complaint did not state a claim cognizable in habeas corpus. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of law, and therefore, relief was unavailable in habeas corpus. View "McKinney v. Haviland" on Justia Law

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The Supreme Court remanded this matter to the trial court to vacate the trial court's decision granting the State's motion to correct Defendant's unlawful sentence eighteen years after the sentence was entered, holding that the State cannot challenge Defendant's voidable sentence through a postconviction motion for resentencing.Defendant pleaded guilty to one count of murder with a three-year firearm specification. Defendant should have been sentenced to an indefinite sentence of fifteen years to life for his murder conviction. The trial court, however, sentenced Defendant to a definite sentence. The State later filed a motion for resentencing. The trial court granted the sentence, and the court of appeals affirmed. The Supreme Court reversed the court of appeals' judgment and remanded the matter for the trial court to vacate the sentencing entry and to reinstate Defendant's original sentence, holding (1) sentences based on an error, including sentences in which a court fails to impose a statutorily mandated term, are voidable if the court imposing the sentence has jurisdiction over the case and the defendant; (2) Defendant's sentence was voidable; and (3) the State cannot challenge a voidable sentence through a postconviction motion for resentencing. View "State v. Henderson" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus against Allen County Court of Common Pleas Judge Jeffrey Reed, holding that the court of appeals properly dismissed the complaint.Appellant pled no contest to pandering. He subsequently sought to withdraw his plea, but the trial court denied the motion. The court of appeals affirmed. Appellant later filed an original action for a writ of mandamus, asking that a certified search warrant be allowed as part of the record. The court of appeals dismissed the complaint, concluding that Appellant had an adequate remedy in the ordinary course of the law. The Supreme Court affirmed, holding that App.R. 9(E) provides an adequate remedy for correcting a record, thereby foreclosing mandamus relief. View "State ex rel. Martre v. Reed" on Justia Law

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The Supreme Court affirmed the decision of the court of appeals reversing the judgment of the trial court dismissing the charges filed against Appellant for failure to pay court-ordered child support based on the Supreme Court's decision in State v. Pittman, 79 N.E.3d 531 (Ohio 2016), holding that Pittman did not apply.The State charged Defendant with two counts of nonsupport of defendants under Ohio Rev. Code 2919.21(B). Defendant filed a motion to dismiss, asserting that he could not be prosecuted for violating the statute because he was not subject to a legal support order at the time he was charged. The trial court granted the motion to dismiss based on its interpretation of Pittman. The court of appeals reversed, concluding that Pittman did not apply to the facts of the present case. The Supreme Court affirmed, holding that the trial court erred in dismissing the charges simply because Defendant's child had been emancipated at the time Defendant was charged. View "State v. Brown" on Justia Law