Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition against an unnamed judge of the Summit County Court of Common Pleas, holding that Appellant's complaint failed to state a claim and was correctly dismissed.Appellant was found guilty of aggravated murder. Because he was charged under Ohio Rev. Code 2903.01(B), which requires that the death occurred during the commission of an underlying felony, and he was acquitted of the alleged underlying felony, Appellant alleged in his complaint that the law required him to be acquitted of aggravated murder. The court of appeals dismissed Appellant's complaint for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding (1) Appellant's mandamus complaint failed to state a claim and was correctly dismissed; and (2) Appellant failed to state a claim for relief in prohibition. View "State ex rel. Zander v. Judge of Summit County Common Pleas Court" on Justia Law

In this original action brought by Cuyahoga County Prosecuting Attorney Michael C. O'Malley seeking a writ of prohibition to prevent Cuyahoga County Court of Common Pleas Judge Michael J. Russo from exercising jurisdiction over a wrongful imprisonment claim filed by Joe D'Ambrosio and a writ of procedendo to compel Judge Russo to terminate D'Ambrosio's litigation, the Supreme Court granted Judge Russo's motion for judgment on the pleadings, holding that O'Malley was not entitled to either writ.D'Ambrosio commenced a wrongful imprisonment action in the common pleas court under Ohio Rev. Code 2743.48. The trial court granted summary judgment for D'Ambrosio. The Supreme Court reversed. Thereafter, D'Ambrosio filed a new complaint in common pleas court again asserting a wrongful imprisonment claim. The State moved for judgment on the pleadings, arguing that the mandate rule and the doctrines of law of the case and res judicata barred the action. The trial court denied the State's motion. The Supreme Court granted Judge Russo's motion for judgment on the pleadings, holding that O'Malley had not alleged facts supporting the issuance of a writ of prohibition or a writ of procedendo. View "State ex rel. O'Malley v. Russo" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that the arguments raised in the petition were not cognizable in habeas corpus.Appellant, an inmate, filed a habeas corpus petition arguing that his sentences were void for several reasons and that the indictment in his first case was invalid. The court of appeals dismissed the petition, concluding that Appellant had an adequate remedy at law to raise most of his claims and that another claim was without merit. The Supreme Court affirmed, holding that Appellant's claims were not cognizable in habeas corpus. View "Smith v. Sheldon" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus to compel the chief of the Ohio Bureau of Sentencing Computation (BSC) to recompute his sentences, holding that although the court of appeals' reasoning was incorrect, its result was correct.Appellant, an inmate, filed a declaratory judgment action against BSC arguing that it had not properly computed state court sentences imposed in 1966 and 1986 and seeking a judgment declaring his proper sentence, parole-eligibility date, and sentence-expiration date. The court of common pleas granted summary judgment for BSC. The court of appeals affirmed. Appellant then filed a writ of mandamus again arguing that the trial court improperly imposed consecutive sentences instead of concurrent sentences. The court of appeals granted the BSC's motion to dismiss for failure to state a claim. The Supreme Court affirmed, holding that because Appellant had an adequate remedy at law to raise his claims, he could not now raise them in a mandamus action. View "State ex rel. Miller v. Bower" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court denying Defendant's motion to suppress a handgun and other evidence obtained during a Terry stop, holding that the stop did not violate the Fourth Amendment to the United States Constitution.After hearing the sound of gunshots, two police officers drove to the area where the shots seemed to be coming from. With their guns drawn, the officers detained Defendant, the only person in the area. The officers patted Defendant down and retrieved a handgun from his jacket. Defendant was charged with carrying a concealed weapon. Defendant filed a motion to suppress, arguing that the officers lacked reasonable suspicion to detain him. The trial court denied the motion to suppress. The court of appeals reversed, concluding that the officers had reasonable suspicion to perform an investigative stop. The Supreme Court reversed, holding that, based on the totality of the circumstances, the police officers had reasonable suspicion to stop Defendant and did not convert the stop into an arrest by approaching Defendant with their weapons drawn. View "State v. Hairston" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus and/or procedendo against Hamilton County Common Pleas Court Judge Melba Marsh, holding that Appellant did not have a clear legal right to require Judge Marsh to physically convey him back to court for a de novo resentencing hearing.Appellant was convicted of murder and sentenced to an indeterminate term of twenty-five years to life imprisonment. Appellant later filed a motion seeking to "Correct Judgment Entry Pursuant to Criminal Rule 36." Judge Marsh overruled the motion. The court of appeals affirmed in part but remanded the matter to the trial court to vacate the portion of the sentencing entry relating to postrelease control. Before Judge Marsh had taken any action on remand, Appellant filed this petition seeking to compel Judge Marsh to convey him to the common pleas court for a new sentencing hearing. Rather than convey Appellant to the trial court Judge Marsh issued an entry vacating his postrelease control sanction. Thereafter, the court of appeals granted Judge Marsh's motion to dismiss. The Supreme Court affirmed, holding that Appellant did not have a clear legal right to be conveyed to court for resentencing. View "State ex rel. Roberts v. Marsh" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for a writ of habeas corpus against the warden of the Chillicothe Correctional Institution, holding that the court of appeals correctly dismissed Appellant's petition.Appellant, an inmate, filed a habeas corpus complaint asserting that his maximum sentence of forty-five years in prison had expired. The court of appeals granted the warden's motion to dismiss, holding that because Appellant had an adequate remedy to raise his claims by way of a postconviction relief petition, Appellant failed to state a claim upon which relief could be granted. The Supreme Court affirmed, holding that the court of appeals did not err in dismissing the petition. View "Ridenour v. Shoop" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's appeal of his conviction for failure to maintain reasonable control of a vehicle, a minor misdemeanor, on the ground that the judgment of conviction was not a final, appealable order because it did not include a sentence, holding that the judgment of conviction was not a final, appealable order.The trial court had discretion to impose a financial sanction on Appellant, but the judgment of conviction contained no sentence. The court of appeals dismissed Appellant's appeal for lack of subject-matter jurisdiction, ruling that there was no sentence imposed on Defendant and, therefore, no final, appealable order. The Supreme Court affirmed, holding that the court of appeals correctly dismissed Appellant's appeal for lack of a final, appealable order. View "State v. White" on Justia Law

The Supreme Court affirmed the decision of the court of appeals dismissing Appellant’s petition for a writ of mandamus against Summit County Common Pleas Court Judge Jill Lanzinger, holding that the court of appeals correctly dismissed the petition.In his petition, Appellant alleged that the trial court lacked jurisdiction over his criminal case because a criminal complaint was never filed against him. Appellant requested the writ compelling Judge Lanzinger to produce the criminal complaint or else dismiss the judgment against him. The court of appeals dismissed the petition sua sponte on the grounds that Appellant failed to comply with the filing requirements of Ohio Rev. Code 2969.25(C). The Supreme Court affirmed, holding that because Appellant did not comply with the requirements of section 2969.25(C) the court of appeals properly dismissed his complaint. View "State ex rel. Powe v. Lanzinger" 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 Appellant’s claim was not cognizable in a habeas corpus action.Appellant was convicted of aggravated murder and murder. After merging the offenses for purposes of sentencing, the trial court sentenced Appellant to life imprisonment with the possibility of parole after twenty years for the aggravated murder conviction. Appellant later filed a habeas corpus petition arguing that his sentence was void because the trial court had improperly imposed multiple sentences for allied offenses. The court of appeals dismissed the petition. The Supreme Court affirmed, holding that the court of appeals correctly dismissed Appellant’s petition. View "Curtis v. Wainwright" on Justia Law