Justia Criminal Law Opinion Summaries

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

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

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

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

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

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction of felony murder based on felonious assault of a child and reckless homicide as a lesser included offense of aggravated murder, holding that the trial court did not err in refusing to provide an instruction on reckless homicide.Defendant was charged with aggravated murder, felony murder, and child endangering. The jury found Defendant guilty of felony murder. As to the aggravated murder charge, the jury found Defendant not guilty, instead finding her guilty of the lesser included offense of reckless homicide. On appeal, Defendant argued that the trial court erred by not giving a reckless homicide instruction as a lesser included offense of felony murder. The court of appeals affirmed. The Supreme Court affirmed, holding (1) because felony murder has no mens rea requirement in regard to the death of a victim, whereas reckless homicide has the mens rea of recklessness, reckless homicide is not a lesser included offense of felony murder; and (2) therefore, the trial court did not err in refusing to give the requested instruction. View "State v. Owens" on Justia Law

The Supreme Court adopted the recommendation of the master commissioner and granted Petitioner's petition for writ of habeas corpus challenging the amount of his pretrial bond, holding that the master commissioner properly stated the facts and applied the law.Petitioner was in jail awaiting trial on multiple charges when he filed his habeas petition. The Supreme Court referred the matter to a master commissioner to conduct a hearing to determine whether Petitioner was being held unlawfully due to an excessive bond. The master commissioner concluded that the $1,000,000 bond on which Petitioner was being held was excessive and recommended modifying the bail to $200,000. The Supreme Court adopted the recommendation and granted the petition for writ of habeas corpus but with certain additional nonfinancial conditions. View "Mohamed v. Eckelberry" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated murder and sentence of death, holding that no prejudicial error occurred in the proceedings below.Specifically, the Supreme Court held (1) the trial court had jurisdiction over the course-of-conduct death-penalty specification; (2) the trial court did not abuse its discretion in admitting evidence relating to the murder; (3) Defendant was not denied his right to an impartial jury due to the seating of certain jurors; (4) the trial court did not deny Defendant his rights to due process and a fair trial by requiring him to wear leg shackles during the trial; (5) the trial court did not err in ruling that an audiovisual-forensics analyst was a lay witness and allowing him to testify; (6) the trial court did not err in admitting Defendant's videotaped phone conversations; (7) the trial court did not err in admitting autopsy photographs into evidence; (8) no plain error occurred from the prosecutor's statements during the mitigation phase of trial; (9) Defendant received effective assistance of counsel; and (10) Defendant's sentence was constitutional. View "State v. Froman" 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 was correct in determining that Appellant's petition failed to state a claim cognizable in habeas corpus.Appellant was convicted of several felony drug-related offenses and sentenced to an aggregate term of thirty-two years' imprisonment. Appellant filed a petition for a writ of habeas corpus alleging that insufficient evidence supported his convictions. The court of appeals dismissed the petition on the grounds that it failed to state a claim cognizable in habeas corpus. The Supreme Court affirmed, holding that the court of appeals did not err. View "Carter v. May" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus on the grounds that his claim lacked merit, holding that Appellant was not entitled to immediate release.Appellant was convicted of felonious assault and sentenced to an indeterminate prison term of eight to twenty-five years in prison. In his habeas corpus petition, Appellant alleged that he had served his prison sentences and was entitled to immediate release. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that because Appellant will not complete his lawfully imposed prison sentences until December 31, 2022, he was not entitled to immediate release. View "State ex rel. Herring v. Wainwright" on Justia Law