Justia Criminal Law Opinion Summaries

Defendant was convicted of felony murder. On appeal, Defendant did not challenge the sufficiency of the jury verdict forms. In postconviction proceedings, however, Defendant did raise an insufficient-verdict-form claim. Both of Defendant’s motions based on claims that the verdict forms were improper were denied. In the instant case, Defendant sought an order compelling the common pleas judge to vacate his sentence and issue a new judgment entry of sentence, arguing that the jury failed to sign the verdict forms for the predicate offense to his felony-murder conviction and, therefore, the jury failed to find him guilty of the necessary predicate offense to that charge, rendering his sentence for felony murder void. The common pleas judge denied relief. The Supreme Court affirmed, holding that Defendant had an adequate remedy in the ordinary course of law by way of his direct appeal, and Defendant’s mandamus claim was barred by res judicata. View "State ex rel. Love v. O'Donnell" on Justia Law

The Supreme Court affirmed the judgment of the appellate court affirming the nineteen-year prison sentence imposed on Defendant at resentencing for his involvement in the robberies of three individuals and the kidnapping of one of those individuals when Defendant was sixteen years old. Specifically, the court held (1) Defendant failed to show that the trial court imposed the sentence as a penalty for exercising his right to a jury trial instead of pleading guilty; (2) the sentence did not violate the Eighth Amendment because it did not involve the imposition of the harshest possible penalties for juveniles, it was proportionate, and there is no national consensus against imposing mandatory sentences on juveniles tried as adults; and (3) Defendant forfeited his argument that the mandatory sentencing scheme set forth in Ohio Rev. Code 2929 violates due process as applied to children. View "State v. Anderson" on Justia Law

Appellant, who was sentenced to a twelve-year term after he was arrested while on parole, filed a petition for a writ of habeas corpus, arguing that the Department of Rehabilitation and Correction improperly calculated his total sentence and violated his due process and equal protection rights by taking him into custody following his arrest without the “required on-site hearing.” The court of appeals dismissed the petition on the basis of res judicata. The Supreme Court affirmed, holding (1) the court of appeals erred by dismissing Appellant’s habeas corpus petition on the basis of res judicata because res judicata is not among the affirmative defenses that may be raised in a Ohio R. Civ. P. 12(B) motion to dismiss; but (2) Appellant’s petition was properly dismissed because it failed to state a claim. View "Johnson v. Moore" on Justia Law

Appellant, an inmate who was serving sentences imposed for his convictions for a variety of offenses, filed an original action in the court of appeals seeking monetary damages from the Madison County Court of Common Pleas, arguing that as a result of the sentence computation of the Bureau of Sentence Computation in the Ohio Department of Rehabilitation and Correction, he was serving for a second time one of the sentences imposed on him by the Madison County Court of Common Pleas, and therefore, he was entitled to damages for false imprisonment. The court of appeals dismissed the action. The Supreme Court affirmed, holding that the State of Ohio, not the common pleas court, was the party that should have been named in this action. View "Johnson v. Madison County Court of Common Pleas" on Justia Law

The Court of Appeals erred on double jeopardy grounds in reversing the trial court’s decision to grant Appellants’ motions to dismiss an indictment that charged them with ethnic intimidation.Appellants filed their motions to dismiss the indictments brought against them in the Scioto County Court of Common Pleas because they had already been convicted in municipal court for aggravated menacing, which is the predicate offense for the charges of ethnic intimidation that were brought against them in the dismissed indictment. The Supreme Court agreed with the decision of the trial court, holding that, for double-jeopardy purposes, Appellants’ aggravated-menacing convictions were the same offenses as those charged in the dismissed indictment. View "State v. Mutter" on Justia Law

To validly impose postrelease control when the trial court orally provides all the required advisements at the sentencing hearing, the sentencing entry must contain certain required information.In 2011, the court of common pleas imposed postrelease control on Defendant as part of his sentence of convictions for robbery and vandalism. While Defendant was under postrelease control, he pled guilty to unlawful sexual conduct with a minor. The trial court sentenced Defendant to a one-year prison term and imposed a judicial-sanction sentence converting the remainder of the postrelease-control term imposed for his 2011 conviction into prison time. After Defendant completed his prison term for unlawful sexual conduct with a minor, he moved the trial court to vacate his judicial-sanction sentence and order his release from prison, arguing that the court did not validly impose postrelease control when it sentenced him for his 2011 convictions. The trial court denied the motion. The court of appeals reversed. The Supreme Court reversed and reinstated the trial court’s judgment, holding that the sentencing entry in this case included all of the required information. View "State v. Grimes" on Justia Law

In State v. Aalim, __ N.E.3d __ (Aalim I), the Supreme Court declared that the Ohio Constitution requires that a juvenile who is subject to mandatory bindover receive an amenability hearing. Implicit in this holding was the conclusion that a juvenile-division judge has discretion in deciding whether to transfer to adult court a juvenile in a case where the juvenile is sixteen or seventeen years old and there is probable cause to believe that the juvenile committed an offense outlined in Ohio Rev. Code 2152.10(A)(2)(b). The Supreme Court then granted the State’s motion for reconsideration, holding that the decision in Aalim I usurped the General Assembly’s exclusive constitutional authority to define the jurisdiction of the courts of common pleas by impermissibly allowing a juvenile division judge discretion to veto the legislature’s grant of jurisdiction to the general division of a court of common pleas over a limited class of juvenile offenders. The court further held that the mandatory bindover of certain juvenile to adult court under Ohio Rev. Code 2152.10(A)(2)(b) and 2152.12(A)(1)(b) does not violate the due course of law clause or the equal protection clause of the Ohio Constitution or the analogous provisions of the Fourteenth Amendment to the United States Constitution. View "State v. Aalim" on Justia Law

After review of Defendant’s first appeal, the Supreme Court affirmed Defendant’s convictions for aggravated murder, aggravated burglary, and aggravated robbery but vacated Defendant’s death sentence. On remand, the trial court again imposed the death sentence. On the second appeal, the Supreme Court again vacated the death sentence on the ground that the trial court had failed to consider Defendant’s allocution. A different judge presided over the third resentencing and again imposed capital punishment. The Supreme Court affirmed, holding that none of Defendant’s four propositions of law warranted relief and that the death penalty in this case was appropriate and proportionate. View "State v. Roberts" on Justia Law

At issue was whether the court of appeals erred in affirming the judgment of the county court of common pleas suppressing evidence seized during the warrantless search of an unattended book bag conducted by a school employee and the school principal. The Supreme Court reversed, holding (1) the school’s protocol requiring searches of unattended book bags to determine ownership and to ensure the safety of its contents furthers a compelling governmental interest in protecting public school students from physical harm; and (2) the school employees’ search of the unattended book bag belonging to Defendant was limited to fulfilling the purposes of the school’s search protocol and was reasonable under the Fourth Amendment. View "State v. Polk" on Justia Law

In 2007, Appellant was charged in Warren County, Ohio with two drug-related felony offenses. Appellant fled the jurisdiction before trial and was later imprisoned in Pennsylvania for federal drug convictions. In 2012, Appellant was extradited to Warren County. Appellant filed a pretrial motion to dismiss the indictment, alleging a violation of Article IV(d) of the Interstate Agreement on Detainers and, alternatively, that he was extradited to Ohio from Pennsylvania without a hearing. The trial court denied the motion to dismiss. Appellant was convicted of the felony charges and sentenced to six years’ incarceration. Appellant then filed a petition for a writ of habeas corpus, alleging that Ohio lacked jurisdiction over him because he was returned to the state pursuant to a defective extradition request. The court of appeals dismissed the motion for failure to state a claim. The Supreme Court affirmed, as “[a] claim of illegal extradition does not state a claim in habeas corpus and will not void [a] conviction.” View "State ex rel. Thomas v. Richard" on Justia Law