Justia Criminal Law Opinion Summaries

The Supreme Court denied the writ of mandamus sought by Alex Penland asking the Court to order the trial court judge to issue findings of fact and conclusions of law as to the denial of Penland's two petitions for postconviction relief, holding that Penland had an adequate remedy at law to address the lack of findings issue.The trial court denied Penland's petitions for postconviction relief without making findings of fact and conclusions of law. The trial court's judgments were affirmed on appeal. Thereafter, Penland brought this mandamus action asking the Supreme Court to order the trial court judge to issue findings of fact and conclusions of law. Penland argued that the trial court's judgments did not constitute final, appealable orders because they lacked findings, and therefore, he was entitled to another appeal. The Supreme Court disagreed, holding that because the trial court's judgments had already been reviewed on direct appeal, Penland had an adequate remedy at law to address the lack of findings issue, precluding mandamus relief. View "State ex rel. Penland v. Dinkelacker" on Justia Law

The Supreme Court affirmed in part and reversed in part Defendant's convictions of, inter alia, three counts of aggravated murder and sentences of death on each count, holding that the trial court erred in convicting Defendant of two counts of kidnapping and further erred in imposing felony-murder death specifications predicated on kidnapping.On independent sentence review, the Supreme Court held that the evidence in the record was insufficient to support two of the kidnapping specifications, which were predicated on kidnapping. The Court affirmed the trial court's judgment in all other respects and affirmed all three sentences of death, holding that there was no other reversible error in the proceedings below. View "State v. Madison" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals upholding the sentence imposed on Defendant for violating the conditions of his community control, holding that Defendant's violation of the condition that he obey all orders of his supervising officer was not a "technical violation," and therefore, the 180-day cap on a prison sentence for a technical violation in Ohio Rev. Code 2929.15(B)(1)(c)(ii) did not apply.Defendant pled guilty to four drug charges and was sentenced to four years of community control. The community control included certain standard conditions that Defendant was alleged to have violated. The trial court found that Defendant's action violated three standard community-control conditions, revoked Defendant's community control, and imposed a thirty-four-month aggregate prison sentence. The court of appeals affirmed. On appeal, Defendant argued that the 180-day cap on prison sentences set forth in section 2929.15(B)(1)(c)(ii) applies to all community-control violations that are not felonies. The Supreme Court affirmed, holding (1) the plain language of the statute does not support Defendant's interpretation that all noncriminal violations constitute "technical violation[s]" under the statute; and (2) Defendant's violation of the second standard condition was not a "technical violation" under section 2929.15(B)(1)(c)(ii). View "State v. Nelson" on Justia Law

The Supreme Court denied Jerone McDougald's original action for a writ of mandamus to compel Larry Greene, the administrative assistance for the warden at the Southern Ohio Correctional Facility, to produce two public records and denied McDougald's request for an award of court costs and for statutory damages, holding that McDougald's request for a writ of mandamus was moot and that McDougald was not entitled to statutory damages.After McDougald filed his complaint for a writ of mandamus, Greene provided both documents to McDougald. Therefore, the Supreme Court dismissed the mandamus claim seeking those documents. The Supreme Court also denied McDougald's request for an award of statutory damages, holding (1) because McDougald did not deliver his two public-record requests by one of the qualifying statutory delivery methods, he was not entitled to an award of statutory damages; and (2) McDougald was not entitled to an award of court costs. View "State ex rel. McDougald v. Greene" on Justia Law

The Supreme Court denied Keontae Stuart's request for a writ of mandamus to compel Larry Greene, the public-records custodian for the Southern Ohio Correctional Facility, to provide Stuart with a document from his public-records request, holding that because Greene eventually did provide a redacted copy of the document to Stuart, this aspect of the case was moot.In his merit brief, Stuart did not challenge the propriety of the redactions but, instead, argued that he was entitled to statutory damages due to Greene's alleged failure to make the record available promptly. The Supreme Court denied Stuart's request for a writ of mandamus compelling the payment of statutory damages, holding that, as a pro se litigant, Stuart was ineligible for an award of attorney fees. The Court also granted Greene's request to keep the supplemental notice sealed to keep the information confidential. View "State ex rel. Stuart v. Greene" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's action seeking a writ of prohibition for failure to state a claim, holding that Appellant possessed an adequate remedy at law.In 1989 and 1990 Appellant was convicted for murder, drug abuse, and assault. In 1993, Appellant filed a petition for postconviction relief from his 1989 convictions. In 1994, Judge Dale A. Crawford of the Franklin County Court of Common Pleas denied the petition. In 1995, Judge Crawford issued a nunc pro tunc entry restating his denial of postconviction relief. In 2018, Appellant filed his complaint seeking a writ of prohibition to invalidate the 1995 nunc pro tunc order. The court of appeals dismissed the action for failure to state a claim. The Supreme Court affirmed, holding that Appellant possessed an adequate remedy at law by appeal in 1994 or in 1995 from the judgments denying his petition for postconviction relief. View "State ex rel. Neguse v. McIntosh" on Justia Law

The Supreme Court denied Petitioner's request for a writ of habeas corpus, holding that Petitioner's allegations did not challenge the jurisdiction of the trial court and were therefore not cognizable in habeas corpus.In 1991, Petitioner was convicted of aggravated burglary and felonious assault. At issue in this case was whether the sentencing statutes in effect in 1991 or the sentencing statutes in effect in 2016 governed Petitioner's sentence. While he was incarcerated, Petitioner filed a petition for a writ of habeas corpus, arguing that he was not sentenced for his 1991 convictions until 2016 when the trial court issued a new sentencing entry for the 1991 convictions, and that in 2016 the trial court should have sentenced him under the statutes that were in effect on that date. The Supreme Court denied relief, holding that Petitioner's claim of sentencing error was not jurisdictional and was not therefore cognizable in habeas corpus. View "McIntyre v. Hooks" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the trial court's denial of Defendant's motion to vacate and/or suspend court costs, holding that the court of appeals erred in concluding that the trial court must consider the defendant's present or future ability to pay court costs in making the discretionary determination of whether to waive, suspend or modify court costs.Defendant was convicted of two counts of murder and ordered to pay court costs. Defendant later moved to vacate and/or suspend the court costs on the grounds that he was indigent. The trial court denied the motion. The court of appeals reversed as to court costs, holding that the trial court abused its discretion by overruling Defendant's motion without considering his indigence and ability to pay. The Supreme Court reversed, holding that a trial court need not consider a defendant's present or future ability to pay when ruling on a motion to vacate, suspend, or modify court costs under Ohio Rev. Code 2947.23(C). View "State v. Taylor" on Justia Law

The Supreme Court affirmed the decision of the court of appeals affirming Defendant's convictions on charges relating to the murder of Robert Williams, holding that there was sufficient evidence to support the convictions.Defendant was convicted and sentenced for aggravated murder, conspiracy, aggravated burglary, and kidnapping. At issue on appeal was whether there was sufficient evidence to support the jury's verdicts that Defendant, who did pull the trigger killing Williams, had conspired to murder Williams and had been complicit in the acts leading to his death. The Supreme Court concluded that the verdicts were based upon sufficient evidence, holding that the evidence of Defendant's involvement in the crimes associated with the killing of Williams was sufficient to find her guilty of the crimes. View "State v. McFarland" on Justia Law

The Supreme Court held that the enhanced penalty for unlawful sexual conduct with a minor does not apply when previous alleged criminal conduct predates the prior conviction, but rather, the enhancement only applies if, at the time of the offense, the offender has previously been convicted of a qualifying sex crime.In 2016, Defendant was convicted of one count of unlawful sexual conduct with a minor, in violation of Ohio Rev. Code 2907.04. In 2017, Defendant was again indicted for unlawful sexual conduct with a minor. The 2017 indictment alleged that the criminal behavior occurred before the 2016 conviction. The 2017 indictment sought to enhance the charges under section 2907.04(B)(4), which elevates the penalty for violating section 2907.04 if the defendant "previously has been convicted of" certain sex crimes. Defendant moved to dismiss the indictment, arguing that the enhancement does not apply when the alleged criminal conduct predates the prior conviction. The trial court granted the motion. The court of appeals reversed. The Supreme Court reversed, holding that, in order for the enhancement to apply, a defendant must have a qualifying conviction when he commits the charged offense. View "State v. Pendergrass" on Justia Law