Justia Criminal Law Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals reversing the trial court's judgment denying jail-time credit for the days Defendant was on postconviction house arrest and postconviction electronic monitoring, holding that Defendant was not entitled to jail-time credit for these days.Defendant pled guilty to a charge involving criminal gang activity and was sentenced to community-control sanctions. Defendant was later placed on house arrest after he violated terms of his community control and was then placed on electronic monitoring after new charges were brought against him. During a hearing, Defendant filed a motion asserting that he was entitled to jail-time credit for the time he was on standard house arrest and electronic monitoring. The trial court denied the motion and imposed a sentence. The appellate court reversed, concluding that Defendant was entitled to jail-time credit for the time he was on house arrest and electronic monitoring. The Supreme Court reversed, holding that Ohio Rev. Code 2969.191(A) is plain and unambiguous, limits a jail-time credit to specific types of confinement, and does not provide for a reduction in sentence for a term of postconviction house arrest or electronic monitoring imposed for violating community-control sanctions. View "State v. Reed" on Justia Law

The Supreme Court affirmed the judgment of the trial court sentencing Defendant to death for the aggravated murders of Casonya C. and Esme K., holding that there was no prejudicial error in the proceedings below.Defendant was found guilty of two aggravated murders and sentenced to death for each aggravated murder. The Supreme Court later vacated the death sentences and remanded the case to the trial court for resentencing. On remand, the trial court again sentenced Defendant to death for the aggravated murders of Casonya and Esme. The Supreme Court affirmed, holding (1) the trial court did not err by denying Defendant's request for individual sequestered voir dire; (2) the trial court did not commit an obvious error in failing to dismiss a prospective juror sua sponte; (3) Defendant did not receive ineffective assistance of counsel during the resentencing hearing; (4) any error with respect to the prosecutor's comments during closing arguments did not prejudicially affect Defendant's substantial rights; and (5) the death sentences in this case were proportionate and appropriate. View "State v. Kirkland" on Justia Law

The Supreme Court vacated this Court's denial of Defendant's motion to supplement and remanded the case to the court of appeals to consider the issue of whether Defendant knowingly, intelligently, and voluntarily waived his right to trial counsel.Defendant filed a motion to supplement the record with the transcript of a hearing, during which Defendant signed a waiver of his right to trial counsel. The transcript had not been included in the record considered by the court of appeals, which overruled Defendant's argument that he did not knowingly, intelligently, and voluntarily waive his right to counsel. The Supreme Court denied the motion to supplement, but, on further consideration, vacated the denial and granted the motion to supplement the record with the transcript of the hearing. Because the court of appeals was not privy to the complete record of the hearing, the Supreme Court remanded the cause to the court of appeals to render an opinion, upon its review of the supplemented record, the issue of whether Defendant knowingly, intelligently, and voluntarily waived his right to counsel. View "State v. Jones" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus against the warden of the Toledo Correctional Institution, holding that the court of appeals correctly dismissed Appellant's petition for a writ of habeas corpus.In dismissing the petition, the court of appeals held that the petition was barred by res judicata and that Appellant had an adequate remedy at law to assert his claims. The court further determined that Appellant had failed to file an affidavit of prior civil actions, as required by Ohio Rev. Code 2969.25(A). The Supreme Court affirmed, holding (1) the court of appeals correctly noted that Appellant's petition was subject to dismissal for his failure to comply with section 2969.25(A); and (2) Appellant was not entitled to file a supplemental brief. View "McDougald v. Bowerman" on Justia Law

The Supreme Court reversed the judgment of the court of appeals to the extent that the court remanded this case to the trial court to correct an entry imposing post release control, holding that the sentencing entry did not include notice of the consequences of violating postrelease control, but that failure rendered the sentence voidable, not void.After the court of appeals affirmed Defendant's convictions and sentence Defendant filed a motion to vacate and release from postrelease control, arguing that the trial court had failed properly to impose postrelease control and, therefore, that part of his sentence was void. The court of appeals remanded the case to the trial court to issue a nunc pro tunc entry correcting the deficiency in the judgment entry, as defined in State v. Grimes, 85 N.E.3d 700 (2017). The Supreme Court reversed, holding (1) when the sentencing court has jurisdiction to proceed to judgment, sentencing errors in imposing postrelease control render the sentence voidable, and the doctrine of res judicata will apply to collateral attacks on the sentence; and (2) Defendant's collateral attack on his sentence was barred by res judicata. View "State v. Hudson" on Justia Law

The Supreme Court answered questions certified by the United States District Court for the Northern District of Ohio, Eastern Division regarding whether a conviction is a condition precedent to civil liability pursuant to Ohio Rev. Code 2307.60.Plaintiff's complaint asserted claims for civil liability pursuant to section 2307.60 for alleged violations of three criminal statutes: Ohio Rev. Code 2921.05 (retaliation), Ohio Rev. Code 2921.03 (intimidation), and Ohio Rev. Code 2921.45 (interfering with civil rights). Defendants filed a motion to dismiss for failure to state a claim because they had not been convicted of the underlying criminal offenses. The federal court denied the motions to dismiss and then certified questions to the Supreme Court. The Supreme Court answered (1) section 2307.60's creation of a civil cause of action for injuries based on a "criminal act" does not require an underlying criminal conviction; and (2) a criminal conviction is not a condition precedent to a civil claim pursuant to section 2921.03. View "Buddenberg v. Weisdack" on Justia Law

The Supreme Court denied the writ of mandamus sought by Relator seeking to compel the production of public records, holding that the evidence established that Respondents did not possess documents responsive to Relator's public-records requests.Relator, an inmate, sent a public-records request requesting several documents. Relator later filed his complaint for a writ of mandamus alleging that he had largely not been provided any documents he sought. The Supreme Court denied Relator's request, holding that Relator's evidence that Respondents had documents responsive to his requests was unpersuasive. View "State ex rel. Hedenberg v. North Central Correctional Complex" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court denying Defendant's motion to withdraw his guilty pleas, holding that Defendant did not meet his burden of establishing that he would not have entered a guilty plea but for the erroneous advice of his plea-stage counsel.Defendant pleaded guilty to sexual battery and attempted induction. Defendant later filed a motion to withdraw his guilty pleas on the grounds that his counsel provided improper advise as to the potential immigration consequences of his pleas. The trial court denied the motion. The court of appeals reversed, holding that counsel was deficient for not "definitively" determining the deportation consequences of Defendant's plea. The Supreme Court reversed, holding that Defendant did not meet his burden of demonstrating that but for his counsel's erroneous advice as to the possibility of relief from deportation he would not have pleaded guilty and would have insisted on going to trial. View "State v. Bozso" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint seeking a writ of mandamus ordering the Meigs County Court of Common Pleas to enter a final, appealable order of conviction, holding that Appellant had no clear legal right to the relief he sought.Defendant was convicted of multiple counts of aggravated murder with death penalty specifications, aggravated kidnapping, and aggravated robbery. Defendant later commenced this action seeking a writ of mandamus ordering the common pleas court to finalize the judgment of conviction and resentence him, arguing that the common pleas court never journalized a final, appealable order of conviction. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that the common pleas court's judgment entry included all the required elements of a valid judgment of conviction and was, therefore, a final, appealable order. View "State ex rel. Lemaster v. Meigs County Court of Common Pleas" on Justia Law

The Supreme Court affirmed Defendant's convictions for aggravated murder, attempted murder, felonious assault, and aggravated arson and sentence of death on the aggravated murder count, holding that no reversible error occurred.Specifically, the Supreme Court held (1) the evidence was sufficient to support the aggravated murder conviction; (2) Defendant's aggravated murder conviction was not against the manifest weight of the evidence; (3) the record did not support Defendant's claim that the trial court denied Defendant standby counsel for the suppression hearing, and the court did not err by allowed Defendant to waive counsel for the mitigation hearing; (4) the trial court's comments prior to the mitigation hearing did not render the mitigation hearing fundamentally unfair; and (5) the death penalty in this case was appropriate and proportional. View "State v. Hundley" on Justia Law