Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the court of appeals’ dismissal of Appellant’s petition for a writ of habeas corpus because his claims were not cognizable in habeas corpus.Appellant pleaded guilty to three counts of rape. The common pleas court sentenced Appellant to nine years’ imprisonment for each count and ordered two of the three sentences to run consecutively. Appellant filed a petition for a writ of habeas corpus arguing that the trial court failed to make the requisite findings under Ohio Rev. Code 2929.14(C)(4) before imposing consecutive sentences. The court of appeals dismissed the petition. The Supreme Court affirmed the dismissal of the petition because Appellant’s claims were not cognizable in habeas corpus. View "State ex rel. Quillen v. Wainwright" on Justia Law

At issue was whether the trial court erred in imposing a sentence, which included both a prison term and community control sanctions at the same time, where the community control sanctions continued after the completion of the prison sentence, which included additional confinement in a community-based-correctional-facility (CBCF).Defendant was sentenced to a prison term for sexual-battery and to community-control supervision for domestic violence. The community-control sentence included several conditions, including the condition that, upon his release from prison for the sexual battery count, Defendant must transfer to a CBCF. The court of appeals vacated the sentence on the domestic-violence count, concluding that the sentence was a split sentence not permitted by statute. The Supreme Court reversed the judgment of the court of appeals and reinstated the sentence imposed on the domestic-violence count except for the condition requiring Defendant’s placement in a CBCF upon his release from prison, which the Court vacated, holding (1) the trial court’s imposition of a CBCF term as a community-control sanction, to be served consecutively to a prison term imposed on a separate offense, was improper; but (2) the property remedy is to vacate only the improperly imposed residential sanction and leave the remaining conditions of the community-control sentence intact. View "State v. Paige" on Justia Law

At issue was whether the trial court erred in imposing a sentence, which included both a prison term and community control sanctions at the same time, where the community control sanctions continued after the completion of the prison sentence, which included additional confinement in a community-based-correctional-facility (CBCF).Defendant was sentenced to a prison term for sexual-battery and to community-control supervision for domestic violence. The community-control sentence included several conditions, including the condition that, upon his release from prison for the sexual battery count, Defendant must transfer to a CBCF. The court of appeals vacated the sentence on the domestic-violence count, concluding that the sentence was a split sentence not permitted by statute. The Supreme Court reversed the judgment of the court of appeals and reinstated the sentence imposed on the domestic-violence count except for the condition requiring Defendant’s placement in a CBCF upon his release from prison, which the Court vacated, holding (1) the trial court’s imposition of a CBCF term as a community-control sanction, to be served consecutively to a prison term imposed on a separate offense, was improper; but (2) the property remedy is to vacate only the improperly imposed residential sanction and leave the remaining conditions of the community-control sentence intact. View "State v. Paige" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court related to Appellant’s second application for postconviction DNA testing under Ohio Rev. Code 2953.71 through 2953.81, holding that Appellant may appeal the trial court’s determination of what constitutes “the results” of the DNA testing.Appellant, who was sentenced to death for first degree murder, sought postconviction DNA testing. The trial court ordered the Ohio Bureau of Criminal Investigation (BCI) to collect DNA evidence from a cigarette butt and, later, to determine the quantity and quality of biological material on ring boxes and shell casings. On appeal, Appellant argued that the State was required to provide him with all documentation relating to the DNA testing of the cigarette butt and that his objection relating to the BCI’s selection as the testing authority and to its preliminary determination as to the scientific suitability for DNA testing of the shell casings and ring boxes should have been upheld. The Supreme Court held that Appellant was entitled to relief on his claim that the trial court failed to provide him with “the results of the testing” as required under section 2953.81(C) and dismissed Appellant’s remaining propositions of law. View "State v. Noling" on Justia Law

The Supreme Court affirmed in part and reversed in part the judgment of the trial court related to Appellant’s second application for postconviction DNA testing under Ohio Rev. Code 2953.71 through 2953.81, holding that Appellant may appeal the trial court’s determination of what constitutes “the results” of the DNA testing.Appellant, who was sentenced to death for first degree murder, sought postconviction DNA testing. The trial court ordered the Ohio Bureau of Criminal Investigation (BCI) to collect DNA evidence from a cigarette butt and, later, to determine the quantity and quality of biological material on ring boxes and shell casings. On appeal, Appellant argued that the State was required to provide him with all documentation relating to the DNA testing of the cigarette butt and that his objection relating to the BCI’s selection as the testing authority and to its preliminary determination as to the scientific suitability for DNA testing of the shell casings and ring boxes should have been upheld. The Supreme Court held that Appellant was entitled to relief on his claim that the trial court failed to provide him with “the results of the testing” as required under section 2953.81(C) and dismissed Appellant’s remaining propositions of law. View "State v. Noling" on Justia Law

The Supreme Court affirmed Defendant’s convictions for three counts of aggravated murder and one count of attempted murder. The court affirmed the trial court’s imposition of three sentences of death but vacated Defendant’s sentence for his noncapital convictions, holding that the sentencing hearing and entry in this case were insufficient to satisfy State v. Bonnell, 16 N.E.3d 659 (Ohio 2014) and that a nun pro tunc entry did not suffice to cure the error. The Supreme Court remanded the cause to the trial court for the limited purpose of conducting a new sentencing hearing consistent with this decision. View "State v. Beasley" on Justia Law

Here, the Supreme Court withdrew its prior opinion affirming the judgment of the court of appeals, which referred this case to a magistrate, who then purported to dismiss the petition sua sponte. Upon further consideration, the Supreme Court concluded that it lacked jurisdiction to hear and decide this case, which Appellant filed in the court of appeals seeking a writ of mandamus against the Ohio Adult Parole Authority. Under Ohio R. Civ. P. 53, a magistrate’s decision, standing alone, is not a final, appealable order, and because the court of appeals did not adopt the magistrate’s decision, Appellant never received a final, appealable order. View "State ex rel. Robinson v. Adult Parole Authority" on Justia Law

The Supreme Court reversed the decision of the court of appeals granting a writ of habeas corpus to Appellee and ordering his immediate discharge from the Ross Correctional Institution. In his petition, Appellee, who was seventeen years old at the time of the offense for which he was convicted, argued that the general division of the common pleas court lacked jurisdiction to try him as an adult because the juvenile court had failed to meet the requirements of Ohio Rev. Code 2152.12(G) before transferring his case. Specifically, Appellee argued that the failure to notify his legal custodian, his grandmother, of the transfer hearing was a violation of the statute, and therefore, the common pleas court lacked jurisdiction over the matter. The court of appeals agreed. The Supreme Court reversed, holding that the juvenile court satisfied the statutory requirements by serving notice on Appellee’s biological mother. View "Turner v. Hooks" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant’s convictions and ordering a new trial, holding that the trial court did not commit plain error in joining for trial two indictments charging Defendant first for aggravated robbery and related charges and later for attempting to intimidate a witness in the robbery case. Although Defendant did not object to the joinder in the trial court, he argued on appeal that the joinder prejudiced him and constituted plain error. The appellate court agreed that the joiner prejudiced Defendant. The Supreme Court reversed, holding that there was no plain error in joining the two cases. View "State v. Gordon" on Justia Law

A law enforcement agency’s policy that an arrestee’s personal effects must accompany the arrestee to jail, on its own, cannot justify the warrantless retrieval of an arrestee’s personal effects from a location that is protected under the Fourth Amendment. Further, a search of personal effects obtained as a result of following such a policy is not a valid inventory search.The Supreme Court reversed the judgment of the court of appeals, which upheld the trial court’s denial of Defendant’s motion to suppress the evidence found during the search of her purse, and vacated Defendant’s convictions for felony possession of drugs and misdemeanor possession of drug paraphernalia and drug-abuse instruments. The court held (1) the removal of Defendant’s purse from a car in which Defendant was a passenger and the subsequent search of the purse was unlawful; and (2) the exclusionary rule applied to require the suppression of the evidence obtained during the unconstitutional search. View "State v. Banks-Harvey" on Justia Law