Justia Criminal Law Opinion Summaries

Defendant entered a no-contest plea to charges of aggravated robbery and aggravated murder with capital specifications. Defendant was sentenced to death for the murder. The Supreme Court affirmed Defendant’s convictions and death sentence, holding (1) Defendant’s constitutional challenges to Ohio’s death penalty laws were unavailing; (2) the trial court erred by denying one of seven pretrial motions Defendant filed, but in so doing, the trial court did not undermine Defendant’s right to a jury trial; (3) the trial court did not err by denying Defendant’s motion to have a copy of the prosecutor’s complete file turned over to the court for review; (4) the trial court correctly denied Defendant’s motions to suppress his confession; (5) the trial court did not err by admitting fingerprint evidence; (6) the prosecutor did not engage in impermissible misconduct; (7) Defendant received effective assistance of counsel; and (8) Defendant’s death sentence was appropriate. View "State v. Belton" on Justia Law

Appellant was convicted of murder. While incarcerated, Appellant filed a motion to vacate his conviction and sentence. When the trial court took no action on his motion, Appellant filed a petition in procedendo in the court of appeals. Thereafter, the county court of common pleas judge denied Appellant’s trial court motion. The judge then filed a motion to dismiss in the procedendo action. The motion was converted to one for summary judgment, and the writ was denied. The Supreme Court affirmed, holding that Appellant’s action in procedendo was moot, as the trial judge ruled on Appellant’s motion to vacate. View "State ex rel. Morgan v. Fais" on Justia Law

John Nye was convicted of a violation of a city ordinance. Judge Lisa Coates, the trial court judge in the case, adopted and approved the magistrate’s decision. However, there was no order in the record that set forth a finding of guilt with the imposition of a sentence. Nye appealed. While the appeal was questioned for want of a final, appealable order, it was ultimately dismissed for failure to prosecute. Thereafter, Nye filed an action in precedendo against Judge Coates. The court of appeals granted the writ, concluding that, in a criminal matter, a trial court must enter judgment separately on all claims and may not simply refer to the magistrate’s decision. Judge Coates subsequently filed a new order that complied with Ohio R. Crim. P. 32(C). Nye appealed, asserting, as he did in the court below, a right to a magistrate’s decision that complies with the form requirements of Ohio R. Crim. P. 19(D)(3)(a)(iii) and a right to findings of fact and conclusions of law from the magistrate. The Supreme Court dismissed the appeal, holding that Nye had an adequate remedy in the ordinary course of law, precluding a writ. View "State ex rel. Nye v. Coates" on Justia Law

Appellant was found guilty of disorderly conduct. In appealing that judgment pro se, Appellant filed a complaint for a writ of mandamus under the same case number as the appeal. Appellant also filed a motion for a stay of the appeal proceedings pending resolution of the mandamus action. The court of appeals struck the complaint on the grounds that a mandamus action is not properly filed as a pleading in a pending appeal. Appellant appealed the court of appeals’ entry striking the mandamus complaint as well as subsequent entries issued by the court of appeals. The Supreme Court dismissed the appeal in part and affirmed in part, holding (1) as to four of the court of appeals’ entries, Appellant’s appeal is dismissed because his notice of appeal is untimely; and (2) to the extent that later entries pertain to Appellant’s mandamus action, the court of appeals is affirmed. View "State v. Henry" on Justia Law

Appellant filed a pleading in the court of appeals entitled “Eighth Admendment [sic] Violation” seeking an order compelling a county jail to send medical records pertaining to treatment he received while he was there to the correctional institution where he is currently incarcerated. The court of appeals construed Appellant’s pleading as a petition for a writ of mandamus and then dismissed his case for failing to follow procedural requirements. The Supreme Court affirmed, holding that the court of appeals did not err by dismissing Appellant’s mandamus petition because he failed to comply with the mandatory filing requirements of Ohio Rev. Code 2969.25. View "State v. Henton" on Justia Law

Appellant, a private citizen, filed a complaint seeking a writ of mandamus compelling Appellees, the Columbiana County clerk of courts and the Columbiana County prosecutor, to accept for filing an affidavit alleging a criminal offense and to prosecute a named individual for perjury. The court of appeals dismissed Appellant’s complaint in mandamus. The Supreme Court affirmed, holding that Appellant had no clear legal right to a prosecution where the clerk had no clear duty to accept Appellant’s affidavit for filing and the prosecutor had no clear duty to prosecute the alleged crime. View "State ex rel. Capron v. Dattilio" on Justia Law

Appellee was arrested for operating a vehicle while under the influence (OVI). Because he had been convicted of OVI five times in the previous twenty years, Appellee was charged with two fourth-degree felonies under Ohio Rev. Code 4511.19(G)(1)(d) and the repeat-OVI specification described in Ohio Rev. Code 2941.1413 for each offense. Appellee moved to dismiss the repeat-OVI specification attached to each count, arguing that section 2941.1413 violates equal protection because it allows the State to seek greater punishment without providing proof beyond that required to trigger section 4511.19(G)(1)(d). The trial court denied the motion to dismiss, and Appellee pled no contest to both counts. The Court of Appeals reversed, holding that section 2941.1413 violates equal protection. The Supreme Court reversed, holding that section 4511.19(G)(1)(d) and section 2941.1413 are part of a logical, graduated system of penalties for recidivist OVI offenses and do not violate equal protection. View "State v. Klembus" on Justia Law

Appellant was convicted of rape of his former stepson and gross sexual imposition on both his former stepson and former stepdaughter. The trial court’s judgment was affirmed on appeal. Appellant later filed a petition for a writ of habeas corpus, arguing that the trial court lacked jurisdiction to convict him of the rape of his former stepson. The Court of Appeals dismissed the petition. The Supreme Court affirmed, holding that Appellant was not entitled to a writ of habeas corpus because the trial court did not lack subject-matter jurisdiction over his case. View "Leyman v. Bradshaw" on Justia Law

James Smith was indicted on one count of aggravated burglary and one count of rape. Smith was subsequently reindicted on the same two counts, in addition to one count of cocaine possession. Thereafter, the trial court dismissed the earlier indictment. Defendant was found guilty of aggravated burglary and rape. Smith later filed a motion for a new trial, arguing that he received ineffective assistance of counsel because he was convicted on a dismissed indictment. The trial court denied the motion. Smith then filed this original action in the Court of Appeals seeking a writ of prohibition against Judge Michael Hall and his successor, Judge Dennis Adkins, asserting that Judge Hall lacked jurisdiction in his case because his conviction arose from an indictment that had been dismissed prior to trial. The Court of Appeals dismissed Smith’s complaint for a writ of prohibition, determining that a writ of prohibition was not appropriate. The Supreme Court affirmed, holding that Appellant had adequate remedies in the ordinary course of law. View "State ex rel. Smith v. Hall" on Justia Law

Appellant was convicted of aggravated murder with two felony-murder specifications. Appellant was sentenced to death. After Appellant exhausted his postconviction and federal remedies, the Supreme Court ordered the execution to proceed on September 15, 2009. During the scheduled execution, attempts to insert an IV catheter were unsuccessful. Appellant was injected eighteen times during the botched attempt. Appellant pursued multiple avenues challenging any further attempt by the State to execute him. This appeal arose from Appellant’s successive petition for postconviction relief, in which he asserted that any future attempt to execute him would violate the Cruel and Unusual Punishments and Double Jeopardy Clauses of the United States and Ohio Constitutions. The trial court denied Appellant’s petition without an evidentiary hearing. The Court of Appeals affirmed. The Supreme Court affirmed, holding that the State was not constitutionally barred from carrying out Appellant’s execution. View "State v. Broom" on Justia Law