Justia Criminal Law Opinion Summaries

In this original action, Relator sought a writ of prohibition to bar the Twelfth District Court of Appeals from hearing the State’s appeal of the trial court’s judgment of acquittal under Ohio R. Crim. P. 29(A). The appellate court filed a motion to dismiss, and Relator asked for leave to amend his complaint. The Supreme Court granted Relator’s motion for leave to amend, denied the appellate court’s motion to dismiss, and granted a peremptory writ of prohibition barring the Court of Appeals from hearing the State’s appeal, holding that the Twelfth District failed to show that it had jurisdiction to hear the State’s appeal. View "State ex rel. Ramirez-Ortiz v. Twelfth District Court of Appeals" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Petitioner’s petition for a writ of mandamus, holding that the claims asserted in the petition were barred by res judicata. Petitioner pleaded guilty, pursuant to a plea agreement, to two counts of aggravated murder. Instead of appealing, Petitioner filed a petition for a writ of mandamus, arguing that the sentencing entry was void and that he was entitled to a new sentencing hearing. The issues for review presented in the mandamus petition were identical to the claims asserted in Petitioner’s motion before the trial court. The court of appeals denied the mandamus petition. The Supreme Court affirmed, holding that the claims asserted in the petition were barred by res judicata. View "State ex rel. Hughes v. Cuyahoga County" on Justia Law

In this original action, Relator requested a writ of prohibition to void the court of appeals’ judgment in the State’s appeal of a judgment granting Relator postconviction relief, to void the common pleas judge’s subsequent orders on remand, and to preclude the court of appeals from ruling on Relator’s direct appeal of the judge’s denial of his motion for a new trial. Upon the State’s appeal, the court of appeals reversed the court of common pleas’ determination that Relator, who was convicted of murdering his former wife, was actually innocent of the aggravated murder and grant of postconviction relief under Ohio Rev. Code 2953.21. On remand, a new common pleas judge reinstated Relator’s aggravated murder conviction and sentence. The Supreme Court denied the writ of prohibition, holding (1) Ohio Rev. Code 2945.67(A) and 2953.23(B) unambiguously allow the State an absolute right to appeal a judgment granting postconviction relief; and (2) therefore, Respondents’ exercise of jurisdiction following the trial court’s judgment was not unauthorized by law. View "State ex rel. Prade v. Ninth District Court of Appeals" on Justia Law

The Supreme Court affirmed Defendant’s convictions of aggravated murder with three death specifications and his sentence of death. The court held (1) the trial court did not err by denying Defendant’s motion for change of venue; (2) Defendant’s trial counsel did not render ineffective assistance in conducting voir dire; (3) the trial court did not err by denying Defendant’s motion to suppress the murder weapon as evidence; (4) the trial court did not err in refusing to suppress Defendant’s post-arrest statements; (5) the evidence was legally sufficient to convict Defendant of tampering with evidence; (6) guilt-phase evidence was properly used against Defendant in the penalty phase; (7) the state did not make improper statements during closing arguments in the penalty phase; (8) there was no error in the trial court’s sentencing opinion; and (9) the death sentence was proportionate to those affirmed in similar cases. View "State v. Martin" on Justia Law

At issue in this case was whether the law-of-the-case doctrine requires a court to apply the findings of a superior court in a criminal case to a civil case brought by the criminal defendant against individuals and entities who were not parties to the criminal case. The court held that the law-of-the-case doctrine does not require a court to follow a superior court’s decision in a prior appeal involving one of the parties but in the context of a different case. Rather, the law-of-the-case doctrine applies only to rulings in the same case. The Supreme Court reversed the judgment of the court of appeals, which ruled that summary judgment was improper in this case because the law-of-the-case doctrine applied. The Supreme Court held that the appellate court’s holding was not a proper application of the law-of-the-case doctrine. View "Reid v. Cleveland Police Department" on Justia Law

Any dismissal of a count in an indictment resolves that count and does not prevent a judgment of conviction from being final and appealable.Defendant was indicted on two counts of kidnapping, two counts of aggravated robbery, and one count of grand theft. The jury returned a verdict of guilty on all counts except the kidnapping counts. The trial court declared a mistrial on the kidnapping counts, and the trial court dismissed those counts. The trial court entered judgment on the convictions. When Defendant appealed his judgment of conviction, the court of appeals dismissed the appeal for lack of a final, appealable order because the trial court had dismissed the kidnapping counts without prejudice. The Supreme Court reversed the judgment of the court of appeals, reinstated Defendant’s appeal, and remanded the cause to the appellate court for further proceedings, holding that a dismissal without prejudice of a count in a multipoint indictment does not prevent the judgment of conviction on the remaining counts from being a final, appealable order. View "State v. Jackson" on Justia Law

The term “harm,” for purposes of Ohio’s kidnapping statute, encompasses not only physical harm but also psychological harm.The kidnapping statute reduces the level of the offense from a first-degree felony to a second-degree felony if the victim is released in a “safe place unharmed.” The court of appeals reversed a first-degree kidnapping conviction based on its determination that there was no physical harm to the victim and that “harm” for purposes of Ohio Rev. Code 2905.01 could not include psychological harm. The Supreme Court reversed, holding (1) the plain meaning of “harm” includes both physical and psychological harm; and (2) counsel was not ineffective in failing to request a safe-place-unharmed instruction, and there was no plain error in the trial judge’s failure to sua sponte provide the instruction. View "State v. Mohamed" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant’s petition for a writ of habeas corpus. Appellant was convicted of aggravated murder, but his conviction was reversed on appeal and remanded. Appellant was subsequently retried and convicted of murder and aggravated murder. In his habeas corpus petition, Appellant asserted that the trial court acted without jurisdiction on remand and also claimed actual innocence. The court of appeals dismissed the petition, ruling that Appellant had been properly convicted by a court of competent jurisdiction and had an adequate remedy at law by which to raise his arguments. The Supreme Court affirmed, holding that Appellant failed to state a proper claim in habeas. View "Swain v. Harris" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant’s petition for a writ of habeas corpus. In his habeas corpus petition Appellant asserted that the common pleas court lacked jurisdiction over his indictment due to alleged problems relating to the charging complaint and his arrest. The court of appeals granted the motion to dismiss filed by Respondent, the warden of the Marion Correctional Institution, on the ground that Appellant failed to submit an affidavit describing his prior civil actions, as required under Ohio Rev. Code 2969.25(A), and that Appellant’s claims were not cognizable in habeas corpus. The Supreme Court affirmed, holding that Appellant’s claims were not cognizable in habeas corpus. View "Patrick v. Bunting" on Justia Law

Appellant failed to disclose his sealed criminal conviction on an application for employment and on applications to renew his registration as an adult-services worker with the Ohio Department of Developmental Disabilities. Consequently, Appellant’s employment was terminated by the Franklin County Board of Developmental Disabilities. The court of appeals affirmed Appellant’s termination. The Supreme Court affirmed, holding (1) the questions on the registration applications that explicitly required disclosure of sealed convictions did not violate Ohio Rev. Code 2953.33(B) because the questions bore a direct and substantial relationship to Appellant’s position and to his qualifications for registration; and (2) Appellant was not excused from answering those questions. View "Gyugo v. Franklin County Board of Developmental Disabilities" on Justia Law