Justia Criminal Law Opinion Summaries

In 2004, a jury found Appellant guilty of aggravated murder. In 2015, Appellant filed a motion to correct the judgment entry. The county court of common pleas judge denied the motion. Appellant subsequently filed an action in mandamus in the court of appeals. The judge filed a motion to dismiss, asserting that Appellant failed to meet the requirements for a late petition for postconviction relief and that his motion to correct the judgment entry was barred by res judicata. The court of appeals granted the motion to dismiss. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of law. View "State ex rel. Bradford v. Dinkelacker" on Justia Law

Defendant pleaded guilty to attempted abduction and was sentenced to a term of community control. The trial court subsequently found that Defendant had violated the terms of his community control and extended the term of community control. Thereafter, the trial court issued an order declaring that the county probation department, rather than the county prosecuting attorney, represents the State in all community control violation proceedings and that the prosecutor would not be notified of any future hearings. The trial court then conducted a community control violation hearing in Defendant’s case. An assistant prosecuting attorney asserted the right to be present and heard. The trial court denied the prosecuting attorney an opportunity to speak. The court found that Defendant had violated the conditions of community control and imposed a fourteen-day jail sentence. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court erroneously vested probation officers, rather than prosecutors, with the authority to represent the interests of the State, and therefore, as the State’s legal representative, the prosecuting attorney is entitled to proper notice and an opportunity to appear and be heard at community control violation proceedings. View "State v. Heinz" on Justia Law

Appellee applied to the court of common pleas to seal his twenty-four-year-old third-degree-felony conviction for receiving stolen property. The State objected to the application, arguing that Appellee’s fourth-degree-misdemeanor conviction under Ohio Rev. Code 4503.11(A) for failing to register a motor vehicle must be counted as a conviction when determining eligibility. The trial court ordered sealed Appellee’s felony conviction for receiving stolen property. The Court of Appeals affirmed. The Supreme Court reversed, holding (1) a violation of section 4503.11 concerning failure to register a motor vehicle must be counted as an offense when determining eligible offender status for record-sealing purposes under Ohio Rev. Code 2953.31; and (2) the Court of Appeals incorrectly held that Appellee was an eligible offender for record-sealing purposes. Remanded. View "State v. J.M." on Justia Law

Appellant pled guilty to several offenses, including gross sexual imposition and three counts of rape. The sentence was memorialized in an entry that recognized 184 days of jail-time credit. Three years later, Appellant filed a motion seeking additional jail-time credit of eighty-seven days for the time he had been held prior to indictment. The trial court denied the motion. Appellant appealed. The court of appeals dismissed the appeal, ruling that the entry appealed from was not a final, appealable order. The Supreme Court reversed, holding that the denial of a motion for jail-time credit pursuant to Ohio Rev. Code 2929.19(B)(2)(g)(iii) is a final, appealable order. Remanded. View "State v. Thompson" on Justia Law

Defendant, a juvenile, was bound over to the common pleas court and indicted on four counts of aggravated murder, among related crimes. Defendant moved to suppress statements he made during a custodial interrogation, arguing that he did not knowingly, intelligently, and voluntarily waive his Miranda rights and that his statements were not voluntary. The trial court denied Defendant’s motion to suppress. Defendant subsequently pled no contest to four counts of aggravated murder, two counts of aggravated robbery, and three counts of tampering with evidence, all with firearm specifications. The Court of Appeals affirmed, holding that where, as in this case, the interrogation of the defendant is recorded electronically, the statements made are presumed to have been made voluntarily pursuant to Ohio Rev. Code 2933.81(B). The Supreme Court reversed, holding (1) section 2933.81(B) does not affect the analysis of whether a suspect intelligently, knowingly, and voluntarily waived his Miranda rights, and therefore, the State retains the burden to prove a valid waiver; and (2) as applied to statements a juvenile makes during a custodial interrogation, the section 2933.81(B) presumption that such statements are voluntary is unconstitutional. Remanded. View "State v. Barker" on Justia Law

Pursuant to a plea agreement, Appellant pleaded guilty to three counts of raping his minor biological daughter. The judge imposed the jointly recommended sentence of three eight-year prison terms to be served consecutively to each other. The court of appeals vacated Appellant’s sentence, holding that while a jointly recommended sentence that is “authorized by law” is not subject to review, Appellant’s sentence was appealable and must be vacated because the trial court did not make the findings required by Ohio Rev. Code 2929.14(C)(4) for imposing consecutive sentences at the sentencing hearing. The Supreme Court reversed, holding (1) compliance with section 2929.14(C)(4) was not necessary because the consecutive sentences were jointly recommended and imposition of consecutive sentences for multiple counts of rape under Ohio Rev. Code 2907.02 is discretionary, not mandatory; and (2) therefore, Appellant’s sentence was “authorized by law” and not subject to review on appeal. View "State v. Sergent" on Justia Law

In 2003, Appellant was convicted of two counts of rape. The sentencing entry stated that Appellant “shall be subject to post release control of up to three years.” The trial court later journalized a nunc pro tunc order correcting the 2003 order by stating that Appellant “shall be subject to post release control of up to five years.” After completing his term of incarceration, Appellant filed a motion to terminate postrelease control. The court of common pleas found that the motion was actually a petition for postconviction relief and dismissed it as untimely. Appellant filed filed an action in mandamus and/or prohibition requesting a writ compelling the trial court to issue a valid final judgment in the underlying case. The court of appeals dismissed the petition, concluding that the trial court lost jurisdiction to take action in the criminal case where Appellant had served the maximum prison term. The Supreme Court affirmed on the basis that Appellant had an alternate remedy in the ordinary course of law by way of appealing the trial court’s dismissal of his motion to terminate his postrelease control. View "State ex rel. Rudert v. Collier" on Justia Law

In 1991, Larry Dawson was convicted of aggravated murder and other crimes. In 2012, Dawson filed a motion for an oral hearing to correct a “void” sentence on the alleged ground that the entry did not address all the charges. Judge Lynne Callahan denied the motion. Dawson appealed. The appellate court concluded that the original sentencing entry was a final, appealable order and that Dawson’s sentencing entry disposed of all charges against him. In 2014, Dawson moved the court to issue a valid judgment. Judge Callahan denied the motion. Dawson then petitioned the Court of Appeals for a writ of mandamus and/or procedendo ordering Judge Callahan and the Summit County Court of Common Pleas (collectively, Respondents) to resentence him and issue a final judgment of conviction. The Court of Appeals concluded that Dawson was not entitled to either writ. The Supreme Court affirmed, holding that because Dawson could have raised the issues in his direct appeal that he asserts now, and because the same issue had already been addressed in the appeal of Dawson’s motion for a new sentence, the case is res judicata. View "State ex rel. Dawson v. Summit County Court of Common Pleas" on Justia Law

After a bench trial, Defendant was found guilty of domestic violence, a misdemeanor in the first-degree. During trial, the victim asserted the privilege against self-incrimination at least eight times in response to questions posed to him about Defendant’s assault. Defendant appealed, raising four claims of error. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by the trial court’s inquiry into the victim’s claim of privilege nor by the trial court’s instruction to the victim to read his prior statement during his examination; (2) Defendant failed to establish that an impermissible judicial bias deprived him of a fair trial; and (3) assuming the trial court erred in allowing the victim to read his prior statement at trial, the error was harmless beyond a reasonable doubt. View "State v. Arnold" on Justia Law

Defendant pleaded guilty to the rape and murder of his grandmother and the murder of her husband. Defendant was sentenced to death for the aggravated murders. The Supreme Court affirmed the convictions and death sentences, holding (1) the trial court did not improperly deny Defendant’s request for self-representation; (2) the trial court did not violate Defendant’s right against self-incrimination when it denied Defendant’s motion to suppress certain statements he made; (3) Defendant’s challenges to the trial court’s evidentiary rulings were unavailing; (4) Defendant’s counsel provided constitutionally effective assistance; (5) any misconduct on the part of the prosecutor was not prejudicial; (6) there were no prejudicial errors in the sentencing opinion; and (7) the imposition of the death sentences was appropriate and proportional. View "State v. Obermiller" on Justia Law