Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that Appellant was not entitled to relief on any of his three propositions of law.Appellant was convicted of an aggravated murder that he committed when he was a juvenile. In his habeas petition, Appellant argued that he was entitled to immediate release because the court of common pleas had lacked subject matter jurisdiction over his case for several reasons. The court of appeals dismissed the complaint, determining that the premise of Appellant's claim was false. The Supreme Court affirmed, holding that the court of appeals properly found that the judgment of conviction and sentence were not void ab initio for lack of subject matter jurisdiction. View "Stever v. Wainwright" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for writs of mandamus and procedendo to compel the court of common pleas judge to issue a judgment of conviction that constitutes a final, appealable order, holding that Appellant had an adequate remedy at law.In 1993, Appellant was convicted of aggravated murder with a firearm specification and other offenses. The court of appeals reduced the aggravated murder conviction to a murder conviction. In 1995, on remand, the trial court entered a modified judgment. Appellant later filed a motion arguing that the modified judgment entry was not a final, appealable order because it did not comply with Crim.R. 32(C). The trial court denied the motion. The court of appeals dismissed the appeal. In 2015, the trial court issued a new judgment of conviction sua sponte. Appellant did not appeal from the new entry. In 2018, Appellant filed an action seeking writs of mandamus and procedendo, arguing that the 2015 judgment of conviction was not a final, appealable order. The court of appeals dismissed the petition, concluding that Appellant had an adequate remedy at law. The Supreme Court affirmed, holding that the court of appeals properly dismissed the petition. View "State ex rel. Bonner v. Serrott" on Justia Law

The Supreme Court reversed the judgment of the court of appeals finding that Defendant's conviction was against the manifest weight of the evidence and reducing her conviction to a lesser included offense rather than ordering a new trial, holding that a new trial is the appropriate remedy when a reviewing court determines that a criminal conviction is against the manifest weight of the evidence.After a bench trial, Defendant was found guilty of assaulting a peace officer. On appeal, the court of appeals determined that Defendant's conviction was against the manifest weight of the evidence, but rather than ordering a new trial, the court of appeals modified the judgment to reduce the conviction to the lesser included offense of disorderly conduct. The Supreme Court reversed, holding that the court of appeals erred by not adhering precedent dictating that a new trial is the appropriate remedy when a reviewing court determines that a criminal conviction is against the manifest weight of the evidence. View "State v. Fips" on Justia Law

The Supreme Court reversed the judgment of the court of appeals and reinstated Defendant's guilty pleas and convictions, reaffirming that trial courts in felony cases must strictly comply with the plea colloquy required by Crim.R. 11(C)(2)(c) and holding that a trial court strictly complies with Crim.R. 11(C)(2)(c) when it orally advises the defendant in a manner reasonably intelligible to the defendant that the plea waives the rights enumerated in the rule.At issue in this case was whether strict compliance with Crim.R. 11(C)(2)(c) requires that the plea colloquy include particular words. Defendant pleaded guilty to certain crimes. On appeal, Defendant argued that the pleas should be vacated because the trial court failed to ensure that he understood that by pleading guilty he was waiving the constitutional rights enumerated in Crim.R. 11(C)(2)(c). The court of appeals vacated Defendant's guilty pleas and reversed his convictions, concluding that the trial court failed to strictly comply with Crim.R. 11(C)(2) by failing to advise Defendant that he would waive his constitutional trial rights by pleading guilty. The Supreme Court reversed, holding that the trial court strictly complied with Crim.R. 11(C)(2)(c) by using easily understood words conveying to Defendant that he would be waiving certain constitutional rights if he were to plead guilty. View "State v. Miller" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of mandamus, holding that Appellant's claim was barred by res judicata.Appellant was convicted of aggravated murder with two firearm specifications. The indictment had contained a count of having a weapon while under disability (WUD), but the court's sentencing entry did not refer to the WUD charge. Appellant later filed a motion for a final, appealable order, arguing that the sentencing entry was void because it failed to dispose of the WUD charge. The trial court denied the motion. Appellant then filed a complaint for a writ of mandamus arguing that the sentencing entry did not dispose of the WUD charge and was not a final, appealable order. The court of appeals dismissed the complaint because Appellant had an adequate remedy in the ordinary course of the law and because Appellant's claim was barred by res judicata. The Supreme Court affirmed, holding that res judicata barred Appellant's mandamus claim because he had raised the same claim multiple times previously. View "State ex rel. Peoples v. Schneider" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing as moot Appellant's complaint for writs of mandamus and procedendo against Clark County Court of Common Pleas Judge Richard J. O'Neill, holding that the court of appeals correctly determined that Appellant's claims were moot.Appellant was found guilty in consolidated cases of murder with a firearm specification and attempted aggravated burglary. Appellant later filed under both case numbers a motion to vacate his postrelease control and a motion for a final, appealable order. The trial court denied the motion for a final, appealable order and granted in part the motion to vacate postrelease control, but the judgment entry did not refer to the motions that Appellant had filed in one of the two cases. Appellant filed a complaint for writs of mandamus and procedendo, arguing that Judge O'Neill had not yet ruled on his motions. Judge O'Neill filed a motion to dismiss, attaching a nunc pro tunc sentencing entry in which the judge effectively denied Defendant's motion to vacate his postrelease-control sentence in the second case. The court of appeals dismissed the claims as moot. The Supreme Court affirmed, holding that Appellant's claims were moot. View "State ex rel. Hibbler v. O'Neill" on Justia Law

The Supreme Court granted Wood County Prosecuting Attorney Paul Dobson's request seeking a peremptory writ of prohibition against Judge Peter Handwork, who presided in two criminal cases finding Andrew Schuman guilty of seven felony counts and who later modified the judgment of sentence, holding that Judge Handwork patently and unambiguously lacked jurisdiction to issue the postjudgment orders.After entry of the judgment of sentence and Schuman's appeal was filed, Judge Handwork considered two motions filed by Schuman and issued two orders modifying the judgment of sentence. Dobson sought a writ of prohibition to vacate the post judgment orders and to prohibit any further exercise of jurisdiction by Judge Handwork. Because Judge Handwork did not file an answer, Dobson also filed a motion for default judgment. The Supreme Court granted the motion for default judgment and issued a peremptory writ of prohibition, holding that Handwork's absence of jurisdiction was patent and unambiguous. View "State ex rel. Dobson v. Handwork" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals convicting Defendant of one count of murder in violation of Ohio Rev. Code 2903.02(A) and one count of murder in violation of Ohio Rev. Code 2903.02(B), holding that the trial court's admission of expert opinion testimony that was not set forth in a written report was harmless error.On appeal, Defendant argued that the state's failure to supply a written report providing the expert's opinions and scientific reasoning violated Crim.R. 16(K) and that the admission entitled him to a new trial. The court of appeals affirmed the convictions. The Supreme Court affirmed, holding (1) it is error to admit expert opinion testimony when the expert's opinion was not submitted in compliance with Crim.R. 16(K); but (2) in the instant case, the trial court's admission of testimony that went beyond the scope of the expert's written report was harmless error. View "State v. Boaston" 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 correctly dismissed the petition because it did not comply with the statutory requirements of Ohio Rev. Code 2969.25(A).Appellant, who was seventeen years old at the time of the alleged offense, was convicted of three counts of murder and other crimes. Appellant was sentenced to an aggregate prison term of forty-one years to life. Appellant later filed a petition for a writ of habeas corpus claiming that the court of common pleas lacked subject matter jurisdiction because the juvenile court failed to make the required findings under Ohio Rev. Code 2152.12(A)(1)(a) before the transfer and challenging the constitutionality of the mandatory transfer procedures. The court of appeals dismissed Appellant's constitutional claims on procedural grounds. The Supreme Court affirmed, holding that Appellant's petition was fatally defective because he did not comply with Ohio Rev. Code 2969.25(A). View "Taylor v. Harris" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming Defendant's conviction for violation of Ohio Rev. Code 4549.02(A)(1) and vacated the conviction, holding that the "registered number" of a vehicle, as used in the statute, is the license plate number associated with the vehicle.The trial court convicted Defendant with the charge of leaving the scene of a motor vehicle accident, concluding that Defendant failed to provide the registered number of his vehicle as required by section 4549.02(A)(1). The court of appeals affirmed on alternative grounds, holding that Defendant violated the statute by not providing the statutorily required identifying information to the police officer at the scene of the accident. The Supreme Court reversed, holding (1) when a driver subject to section 4549.02(A)(1) gives the information specified in that statute to the required recipients under section 4549.02(A)(1)(a) and (b), the driver does not violate section 4549.02(A)(1) by not providing that information to a police officer if the driver leaves the scene without knowledge that the police have been alerted of the accident; and (2) the registered number of a motor vehicle is the license plate number associated with the vehicle. View "State v. Bryant" on Justia Law