Justia Criminal Law Opinion Summaries

A complaint was filed in the juvenile court alleging that Appellant engaged in conduct that would be considered aggravated robbery if committed by an adult. Appellant was sixteen years old at the time of the alleged offense. The State filed a motion to transfer Appellant to the general division of the common pleas court to be tried as an adult pursuant to Ohio Rev. Code 2152.10(A)(2)(b) and 2152.12(A)(1)(b), which provide for mandatory transfer of juveniles to adult court in certain circumstances. After a hearing, the juvenile court automatically transferred the case. Appellant moved to dismiss the ensuring indictment charging him with two counts of aggravated robbery with accompanying firearm specifications and transfer his case back to juvenile court, arguing that mandatory transfer of juveniles is unconstitutional. The trial court overruled the motion. Appellant subsequently entered pleas of no contest to the two counts of aggravated robbery. The court of appeals affirmed. The Supreme Court reversed, holding that mandatory transfer of juveniles to adult court without providing for the protection of a discretionary determination by the juvenile court judge violates juveniles’ right to due process. View "State v. Aalim" on Justia Law

After a jury trial, Appellant was found guilty of two counts of murder. The trial court sentenced Appellant to death. The Supreme Court affirmed. Appellant later filed an amended application for postconviction DNA testing pursuant to Ohio Rev. Code 2953.71 through 2953.84. The county common pleas court denied the application. Appellant appealed, arguing that section 2953.73(E)(1) violates the Eighth and Fourteenth Amendments because it discriminates between capital and non-capital criminal defendants, fails to provide appellate review, and results in the arbitrary and capricious application of the death penalty. The Supreme Court held (1) section 2953.73(E)(1) violates the constitutional right to equal protection, but the unconstitutional portion of the statute can be excised to create a constitutionally sound procedure that provides capital offenders an appeal of right to the Supreme Court; and (2) this constitutional analysis applies equally to section 2953.72(A)(8), which summarizes the procedure for appealing a denial of postconviction DNA testing. Therefore, the Court applied the severance remedy to the unconstitutional portions of the statutes. Consequently, Appellant will be permitted an appeal of right to the Supreme Court from the denial of his amended application for postconviction DNA testing. View "State v. Noling" on Justia Law

Relators filed this original action in mandamus seeking the release of video from a camera worn by an officer who shot a motorist after a traffic stop. Relators asserted that Respondent, the prosecuting attorney, violated the Public Records Act by failing either to make the body-camera video available for inspection and copying or to prove that it was exempt from disclosure. The prosecutor released the video two days after the complaint was filed. The Supreme Court dismissed the writ of mandamus as to certain relators because the relators failed to request the record from the prosecutor’s office and denied the writ as to other relators because the body-camera video had already been produced. Because the video was produced within a reasonable amount of time, the request for statutory damages and attorney fees was also denied. View "State ex rel. Cincinnati Enquirer v. Deters" on Justia Law

Appellee was an eighteen-year-old high school student when he allegedly committed criminal acts that led to his conviction of attempted robbery and attempted complicity in the commission of intimidation. Appellee later applied to the trial court to seal the records pertaining to his conviction. The State argued that Ohio Rev. Code 2953.36 prohibiting the sealing of the record of Appellee’s conviction because the statute prohibits the sealing of records of convictions of an offense of violence when the offense is a felony. The trial court denied Appellee’s application. The court of appeals reversed. The Supreme Court reversed, holding that attempted robbery is a crime of violence and that, pursuant to section 2953.36, a person convicted of attempted robbery is ineligible to have the record of that conviction sealed. View "State v. V.M.D." on Justia Law

After a jury trial, Appellant was convicted of aggravated murder and other offenses. The trial court sentenced Appellant to death for the murder conviction. The Supreme Court affirmed Appellant’s convictions and sentence, holding (1) the trial court did not err in admitting statements Appellant made during his interview with police; (2) Appellant did not receive ineffective assistance of counsel during voir dire or during trial; (3) the trial court did not err by failing to hold a hearing to determine a witness’s competency to testify; (4) the trial judge was not biased against Appellant, and the trial judge did not err by refusing to grant a mistrial for the judge’s alleged biased interjections; (5) Appellant failed to establish plain error regarding the prosecutor’s closing statements; and (6) Appellant’s sentence was appropriate and proportional. View "State v. Cepec" on Justia Law

After a jury trial, Defendant was convicted of eleven counts of aggravated murder, each containing death-penalty specifications. The trial court sentenced Defendant to death on each of the eleven counts. The Supreme Court affirmed, holding (1) courtroom closures did not deny Defendant his Sixth Amendment right to a public trial; (2) pretrial publicity did not deny Defendant a fair trial, and the trial court did not abuse its discretion by denying Defendant’s requests for a change of venue; (3) the trial court did not impermissibly restrict voir dire of prospective jurors or abuse its discretion in denying challenges for cause to a number of prospective jurors; (3) the trial court did not act arbitrarily by permitting jurors to use their initials to signify assent to verdicts; (4) Defendant’s arguments regarding the manner in which the death specifications were alleged in the indictment and with the instructions submitted to the jury were unavailing; (5) the trial court did not err in its instructions to the jury during the penalty phase; (6) Defendant’s counsel did not render ineffective assistance of counsel; (7) Defendant’s constitutional challenges to death penalty statutes failed; and (8) the death sentences in this case were appropriate and proportionate when compared with similar capital cases. View "State v. Sowell" on Justia Law

In 1998, Appellee was sentenced to thirteen years in prison on various drug and weapons charges. The district court granted Appellee’s writ of habeas corpus and ordered the state to release Appellee or grant him a new trial within a certain time. The state did not retry Appellee, and the charges against him were dismissed with prejudice. Thereafter, Appellee filed a complaint seeking a determination that he was a wrongfully imprisoned individual. The trial court granted summary judgment in favor of the state. The court of appeals reversed. The Supreme Court reversed the judgment of the court of appeals and remanded with instructions to apply Mansaray v. State. On remand, the court of appeals again reversed the grant of summary judgment to the state, ruling that Appellee had satisfied all five elements of Ohio Rev. Code 2743.48(A). The Supreme Court reversed, holding that Appellee failed to satisfy all five elements of section 2743.48(A). View "James v. State" on Justia Law

During the course of grand jury proceedings, the state issued eight grand jury subpoenas seeking documents and testimony to individuals associated with Appellants. Appellants moved to quash the subpoenas, arguing that they required Appellants and their former attorneys to disclose information protected by the attorney-client privilege, the attorney work-product doctrine, and the common-interest doctrine. The trial court denied the motions. Appellants appealed the trial court’s order. The court of appeals dismissed the appeal for lack of a final order. The Supreme Court reversed, holding that an order denying a motion to quash a grand jury subpoena and ordering a party to testify or produce documents is a final order that may be appealed. Remanded. View "In re Grand Jury Proceedings of John Doe" on Justia Law

In 1995, Defendant was convicted of felonious assault on a police officer. After being released on parole, Defendant pleaded guilty in 2011 to resisting arrest, was given a suspended sentence, and was placed on community control. In 2013, Defendant stipulated to a violation of his community-control sanctions and was ordered to serve the sentence for the 2011 resisting-arrest conviction. In 2015, after Defendant had completed his resisting-arrest sentence, the parole board found that Defnedant had violated his parole for the 1995 sentence and imposed an additional term of confinement on that basis. Defendant filed this action in habeas corpus claiming that the board did not have authority to extend his incarceration. The court of appeals dismissed the action on the basis that Defendant failed to attach all his commitment papers to his petition. The Supreme Court affirmed on another ground, holding that Defendant failed to comply with the requirements of Ohio Rev. Code 2969.25 by filing an affidavit of indigence without attaching a statement of his inmate balance for each of the preceding six months. View "Robinson v. Miller" on Justia Law

Appellant was the defendant in a criminal case in which he was found not guilty by reason of insanity and found to be a mentally ill person subject to hospitalization by court order. In 2014, Appellant filed a motion asserting that the trial court lacked authority to order his original commitment. The trial court denied relief, and Appellant appealed. In 2015, Appellant filed a motion to terminate his involuntary confinement. The trial court stayed the action pending the outcome of Appellant’s appeal from the denial of the 2014 motion. Thereafter, Appellant filed a petition for writs of mandamus and procedendo requesting that the trial court judge be ordered either to grant or hold a hearing on the 2015 motion. The court of appeals ultimately affirmed the trial court’s denial of the 2014 motion. In 2016, the court of appeals dismissed Appellant’s petition for writs of mandamus and procedendo, concluding that the request for a writ of procedendo was moot and that the judge had not abused his discretion in issuing the stay. The Supreme Court affirmed, holding that the case was moot, and the the trial court did not err in failing to consider the 2015 motion earlier. View "State ex rel. Rohrer v. Holzapfel" on Justia Law