Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's habeas corpus petition against the warden of the Marion Correctional Institution (MCI), holding that Appellant's petition was barred by res judicata.Appellant, an inmate at MCI, filed a successive petition for a writ of habeas corpus alleging that his maximum aggregate sentence had expired. The court of appeals dismissed the action, holding that habeas corpus does not lie because Appellant's maximum aggregate sentence will not expire until June 2023 and that the petition was barred by res judicata as a successive habeas petition. The Supreme Court affirmed, holding that the court of appeals properly granted summary judgment on res judicata grounds. View "Dailey v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction for sexually abusing his granddaughter, holding that acquitted-act evidence was admitted for a proper purpose under Evid.R. 404(B).During trial, the trial court allowed the State to introduce "other acts" evidence that Defendant had previously molested his daughter under similar circumstances. Defendant was put on trial for these allegations but was ultimately acquitted. On appeal, Defendant asked the trial court to categorically rule that admitting evidence related to crimes for which a defendant has been acquitted violates the Double Jeopardy Clause of the Ohio Constitution. The Supreme Court rejected the challenge, holding (1) the Double Jeopardy Clause does not impose a per se bar to the use of other-acts evidence for which the defendant was previously acquitted; and (2) because Defendant placed his intent at issue, the trial court properly admitted evidence of the prior sexual-assault allegations. View "State v. Smith" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing Defendant's convictions of two counts of rape, holding that the trial court erred by admitting "other acts" evidence that Defendant had sexually abused his stepdaughter when she was a child.Defendant was convicted of raping an adult female acquaintance. During trial, the trial court allowed the State to present evidence that Defendant had victimized his former stepdaughter as a child. The court of appeals reversed Defendant's convictions, concluding that the evidence of Defendant's abuse of his stepdaughter constituted improper other-acts evidence and was inadmissible under Evid.R. 404(B). The Supreme Court affirmed, holding that the evidence of Defendant's other acts constituted improper propensity evidence, and the trial court erred in admitting it. View "State v. Hartman" on Justia Law

The Supreme Court granted a writ of mandamus to compel the Ohio Department of Rehabilitation and Correction and its director (collectively, DRC) to revise their calculation of Charles Fraley's prison sentence, holding that Fraley was entitled to a writ of mandamus compelling DRC to correct its records.In this case, the sentencing court imposed an aggregate sentence of ten years. However, DRC computed Fraley's sentence to be an aggregate term of thirteen years. In his petition for a writ of mandamus Fraley argued that DRC was under a clear legal duty to follow the sentencing judge's entries. The Supreme Court agreed, holding (1) Fraley did not have an alternative remedy that would preclude the possibility of a writ of mandamus; and (2) DRC had a clear legal duty to carry out the sentence that the trial court imposed. View "State ex rel. Fraley v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's petition for a writ of mandamus and declared Appellant to be a vexatious litigator under S.Ct.Prac.R. 4.03(B), holding that the court of appeals was correct in denying the writ and that Appellant was a vexatious litigator.Appellant was convicted of three counts of aggravated robbery with firearm specifications and sentenced to more than thirty years in prison. Appellant later filed a petition for writ of mandamus seeking to compel Judge Lindsay Navarre to resentence him. The court of appeals concluded that Appellant had an adequate remedy in the ordinary course of law and denied the writ. The Supreme Court affirmed, holding (1) Appellant had an adequate remedy in the ordinary course of law; and (2) Appellant's raising of repetitive and unmeritorious arguments that this Court had already rejected was frivolous conduct under S.Ct.Prac.R. 4.03(A) and (B). View "State ex rel. Hill v. Navarre" on Justia Law

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