Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the trial court denying Appellant’s second-degree application for DNA testing, holding that Appellant was not entitled to the relief he sought.Appellant was convicted of two counts of aggravated murder and sentenced to death. This appeal was taken from the trial court’s denial of Appellant’s second-degree application for DNA testing. On appeal, Appellant presented two propositions of law for the Supreme Court’s consideration. The Court denied relief, holding (1) this Court lacked jurisdiction to consider Appellant’s first proposition of law; and (2) Appellant failed to show any of the evidence he sought to have tested could be outcome determinative. View "State v. Bonnell" 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 properly determined that res judicata precluded Appellant from raising his claim in this habeas corpus petition.In his petition, Appellant argued that the trial court lacked jurisdiction to convict him because the juvenile court had not conducted a bindover proceeding as required by Ohio Rev. Code 2152.12 and Juv. R. 30. The court of appeals dismissed the petition, ruling that Appellant had an adequate remedy in the ordinary course of the law through which he could raise his bindover claim and that his habeas claim was barred by res judicata. The Supreme Court affirmed on res judicata grounds, holding that res judicata precluded Appellant from using habeas corpus to gain successive appellate review of this previously litigated issue. View "Lopez v. Warden" 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 properly dismissed Appellant’s petition for failure to attach the statement of his inmate account that is required by Ohio Rev. Code 2969.25(C).The court of appeals sua sponte dismissed Appellant’s petition due to his failure to abide by the mandatory filing requirements of section 2969.25. On appeal, Appellant argued that the Court should excuse his noncompliance with the technical requirements of the statute and challenged the constitutionality of the statute on its face and as applied. The Supreme Court rejected Appellant’s arguments on appeal, holding that Appellant’s petition for a writ of habeas corpus was properly dismissed. View "Rogers v. Eppinger" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant’s petition for writs of mandamus and prohibition against Robert C. McClelland, a Cuyahoga County Common Pleas Court judge, holding that Appellant was not entitled to either writ.Appellant pleaded guilty to five counts of gross sexual imposition and was sentenced to fifteen years’ imprisonment. Appellant later filed a petition for writs of mandamus and prohibition in the court of appeals seeking an order compelling Judge McClelland to vacate as void a journal entry dismissing the first indictment in his criminal case. The court of appeals concluded that the trial court properly dismissed the first indictment and that Appellant had an adequate remedy in the ordinary course of law. The Supreme Court affirmed, holding that, even if the dismissal had been granted in error, Appellant did not demonstrate that he lacked an adequate remedy in the ordinary course of law. View "State ex rel. Steele v. McClelland" on Justia Law

The Supreme Court reversed the judgment of the Court of Appeals affirming the trial court’s suppression of 150 individually wrapped pieces of marijuana-infused candy contained in two sealed Priority Mail envelopes located inside an open box on the back seat of Defendant’s vehicle during a traffic stop, holding that the search of the envelopes and the duration of the traffic stop were not in violation of Defendant’s constitutional rights.Specifically, the Court held that after finding marijuana and other drug paraphernalia in Defendant’s car, the arresting officer had probable cause to open the envelopes and had the right to detain Defendant for as long as reasonably necessary to complete the search of the vehicle. View "State v. Vega" on Justia Law

The Supreme Court affirmed Defendant’s conviction of aggravated murder and sentence of death, imposed after the case was remanded for resentencing, holding that none of Defendant’s propositions of law on appeal warranted reversal.Specifically, the Court held (1) the trial court did not err when it excluded testimony that Defendant sought to present as additional mitigating evidence in the time between the two sentencing hearings; (2) the trial court did not violate Defendant’s due process rights by refusing to empanel a new jury for the resentencing hearing; (3) trial counsel did not provide ineffective assistance at the resentencing hearing; (4) Defendant was not denied the opportunity to deny or explain evidence at the resentencing hearing; and (5) Defendant’s sentence of death was appropriate and proportional. View "State v. Goff" on Justia Law

The Supreme Court held that using a prior juvenile adjudication of delinquency for the commission of an offense that would have been felonious assault if committed by an adult as an element of the offense of having a weapon under disability, as set forth in Ohio Rev. Code 2923.13(A)(2), does not violate due process under the Ohio or United States Constitutions.Appellant was indicted on one count of having a weapon while under a disability. The alleged disability stemmed from Appellant’s prior adjudication of delinquency as a juvenile for committing a felonious assault. Appellant filed a motion to dismiss, asserting that his juvenile adjudication could not be used as a predicate for criminal conduct under section 2923.13(A)(2). The trial court denied the motion to dismiss. Appellant was subsequently convicted and sentenced. The court of appeal affirmed. The Supreme Court affirmed, holding that a previous juvenile adjudication may be an element of the weapons-under-disability offense set forth in section 2923.13(A)(2) without violating due process. View "State v. Carnes" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals that affirmed Appellant’s convictions and sentence, holding that the juvenile court’s failure to consider and apply Ohio Rev. Code 2152.021 - Ohio’s safe harbor law that benefits certain human-trafficking victims charged with juvenile delinquency - did not invalidate the court’s discretionary transfer of Appellant’s case to adult court.The juvenile court in this case found that Appellant had suffered a “very clear history of human trafficking.” Despite this finding, the juvenile court did not make any finding with respect to whether the charges related to Appellant’s victimization and did not appoint a guardian ad litem for her in the juvenile court. The court then transferred her case to adult court. Appellant pled guilty to aggravated murder and was sentenced to twenty-one years in prison. The court of appeals affirmed, holding that by pleading guilty, Appellant had waived her ability to raise the juvenile court’s error in failing to consider section 2152.021(F). The Supreme Court affirmed, holding (1) because Appellant did not object to the juvenile court’s failure to consider the applicability of section 2152.021(F), the criminal plain-error standard applied; and (2) Appellant did not carry her burden of demonstrating plain error. View "State v. Martin" on Justia Law

At issue was whether an exception in Ohio law providing that jail-time credit does not apply to the portion of a prison sentence that is imposed for a firearm specification, as applied in this case, violates equal-protection guarantees.Defendant was sentenced to an aggregate prison term that included two mandatory terms for firearm specifications. Before sentencing, Defendant filed a motion to credit the time that he had served in jail prior to sentencing toward the four years that he needed to serve for the firearm specifications. The trial court determined that the jail-time credit should be applied only to Defendant’s prison terms imposed for the underlying felonies. The court of appeals reversed, concluding that the failure to apply jail-time credit to Defendant’s firearm-specification terms would risk an equal protection violation should Defendant be granted judicial release. The Supreme Court revered, holding (1) the plain language of Ohio Rev. Code 2929.14(B)(1)(b) does not allow jail-time credit to be applied to mandatory firearm-specification sentences; and (2) there was no equal protection violation in this case. View "State v. Moore" on Justia Law

The Supreme Court granted Cuyahoga County Prosecuting Attorney Michael C. O’Malley a writ of prohibition and ordered Cuyahoga County Common Pleas Court Judge Cassandra Collier-Williams to vacate her journal entry granting intervening-respondent Kelly Foust’s renewed motion for a capital resentencing hearing before a jury, holding that Judge Collier-Williams patently and unambiguously lacked jurisdiction to empanel a jury for a resentencing hearing in this capital-murder case when Foust validly waived a jury trial.Foust filed a renewed motion for a penalty phase hearing before a jury based on Hurst v. Florida, __ U.S. __ (2016), arguing that Hurst guaranteed a capital defendant an unequivocal right to a jury determination of every fact necessary to impose a death sentence and that he was entitled to withdraw his earlier jury waiver. The judge granted Foust’s renewed motion. The Supreme Court granted O’Malley a writ of prohibition, holding that O’Malley established that Judge Collier-Williams patently and unambiguously lacked jurisdiction to invalidate Foust’s previous jury waiver and empanel a jury for his resentencing hearing. View "State ex rel. O'Malley v. Collier-Williams" on Justia Law