Justia Criminal Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus sought by Appellant to compelling the Clark County Prosecuting Attorney to join in the filing of a motion to vacate guilty pleas Appellant had entered in two criminal cases, holding that Appellant's claim was not cognizable in mandamus.In his writ of mandamus, Appellant sought to compel the Clark County prosecuting attorney to join in the filing of a motion to vacate the guilty pleas that Appellant entered in two criminal cases. The court of appeals denied the writ on the grounds that Appellant had adequate remedies in the ordinary course of the law and that his claim was barred under the doctrine of res judicata. The Supreme Court affirmed on different grounds, holding that Appellant's claim seeking to enforce an alleged contractual duty was not cognizable in mandamus. View "State ex rel. Duncan v. Driscoll" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting the trial court's motion to dismiss this complaint brought by Appellant seeking an order requiring the trial court to issue a final, appealable order regarding two criminal convictions, holding that the court of appeals did not err.Appellant, who pleaded guilty to the lesser offenses of gross sexual imposition and burglary, brought a complaint for a writ of mandamus alleging that because there was no entry that disposed of the original charges of rape and aggravated burglary, no final, appealable order had been issued, and seeking a final appealable order that complied with Crim.R. 32(C). The court of appeals dismissed the action. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law, and therefore, he was not entitled to relief in mandamus. View "State ex rel. Mitchell v. Pittman" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Relator's petition seeking a writ of prohibition to vacate his conviction and sentence for certain felony offenses, holding that Relator failed to show that he was entitled to the writ.In his petition, Relator sought a writ of prohibition to, among other things, prohibit and vacate the transfer of his criminal case from one judge to another. The court of appeals granted the judges' motion to dismiss the petition. The Supreme Court affirmed, holding that Relator failed to show by clear and convincing evidence that he was entitled to a writ of prohibition, as he had an adequate remedy in the ordinary course of the law, and the trial court did not patently and unambiguously lack subject-matter jurisdiction. View "State ex rel. Smith v. Triggs" on Justia Law

The Supreme Court denied as moot Mark Griffin's request for a writ of mandamus and also denied Griffin's request for statutory damages, holding that Griffin's request for a writ of mandamus was moot.Griffin, an inmate at the Toledo Correctional Institution, submitted a public-records request to Allan Szoke, a warden's assistant at the Ohio Department of Rehabilitation and Correction. Griffin later brought this action seeking a writ of mandamus compelling production of the records and an award of statutory damages. The Supreme Court denied the writ, holding (1) because Griffin had received the requested records, his request for a writ of mandamus was moot; and (2) Griffin was not entitled to statutory damages because he did not clearly and convincingly show that Szoke denied his public-records request or otherwise failed to fulfill his duties under the Public Records Act. View "State ex rel. Griffin v. Szoke" on Justia Law

The Supreme Court denied a writ of mandamus brought under Ohio's Public Records Act, Ohio Rev. Code 149.43, by Harry Barr, an inmate at the Grafton Correctional Institution (GCII), seeking to compel the warden's assistant at GCI to produce the job description for, and the certification or license held by, Jennifer Whitten, a GCI employee, holding that Barr was not entitled to the writ.In addition to the writ of mandamus, Barr sought statutory damages and also filed a complaint for a temporary restraining order (TRO) and a preliminary injunction and other motions. The Supreme Court dismissed Barr's complaint for a TRO and a preliminary injunction, granted Barr's motion to amend the evidence and deemed the record supplemented, granted his motion to withdraw his motion for an order pursuant to S.Ct.Prac.R.4.01(A), and denied the writ of mandamus and his request for statutory damages, holding that Barr was entitled to some relief. View "State ex rel. Barr v. Wesson" on Justia Law

The Supreme Court granted Harry Barr a limited writ of mandamus, holding that Barr was entitled to relief on his request for certain inmate records predating State ex rel. Mobley v. Ohio Dep't of Rehabilitation & Correction, 201 N.E.3d 853 (Ohio 2022).Barr, an inmate, sought certain documents from James Wesson, the institutional public information officer at Grafton Correctional Institution (GCI), pursuant to Ohio's Public Records Act, Ohio Rev. Code 149.43. Wesson produced some records and, as to the remaining, claimed that Barr failed sufficiently to specify which records he wanted and that Barr's requests predated Mobley, thus rendering them unenforceable. The Supreme Court granted Barr a limited writ of mandamus as to prison-kite logs predating Mobley, ordered Wesson to produce the email messages that Barr requested if they exist, denied the writ as to Barr's request for a list of cross-gender employees, dismissed his complaint for a temporary restraining order and preliminary injunction, and denied his motion to strike a certain affidavit, holding that Barr demonstrated that he had a clear legal right to access the prison-kite logs and specified email messages if they existed. View "State ex rel. Barr v. Wesson" on Justia Law

The Supreme Court affirmed in part and reversed in part the decision of the court of appeals in this case involving Ohio's sex-offender registration and reporting laws, holding that Appellant had completed his Ohio sex-offender registration and reporting obligations.Specifically, the Court held (1) the holding in State v. Henderson, 162 N.E.3d 776 (Ohio 2020), that when a court has jurisdiction to act, any errors in the court's judgment are voidable and subject to res judicata if they are not timely appealed, does not apply to a trial court's erroneous classification of a defendant as a Tier I sex offender subject to the registration and reporting requirements of Ohio's Adam Walsh Act (AWA), 2007 Am.Sub.S.B. No. 10, when the date on which the defendant committed the offense rendered the defendant subject to the registration and reporting requirements of Ohio's Megan's Law, Am.Sub.H.B. No. 180, and Ohio's sex-offender registration and reporting scheme that predated the AWA, Am.Sub.S.B. No. 5; and (2) a person's obligation to register and report as a sex offender in Ohio for a specific duration is not tolled when the person was convicted of a sexually-oriented offense in Ohio but resides in a different state and reports as a sex offender regarding the out-of-state offense. View "State v. Schilling" on Justia Law

The Supreme Court affirmed the judgment of the of the court of appeals dismissing Appellant's petition for a writ of habeas corpus, holding that Appellant did not comply with Ohio Rev. Code 2969.25(C).Defendant was found guilty on multiple felony counts and sentenced to twenty years in prison. While incarcerated, Defendant filed a petition for a writ of habeas corpus. The court of appeals granted the warden's motion to dismiss on the grounds that, among other things, Defendant's claim failed to comply with Ohio Rev. Code 2969.25(C). The Supreme Court affirmed, holding that the court of appeals did not err in finding Defendant's noncompliance with section 2969.25(C) to be a basis for dismissal. View "State ex rel. Sands v. Lake County Common Pleas" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying Appellant's petition for a writ of mandamus against the Hamilton County clerk of courts (Appellee) to compel the production of public records and awarded him $700 in statutory damages, holding that Appellant failed to prevail on his claims.Appellant, an inmate, sent public records requests to the clerk, who informed Appellant that his requests were subject to approval from the judge who sentenced him or their successor according to Ohio Rev. Code 149.43(B)(8). Appellant filed a petition for a writ of mandamus challenging the clerk's response. The petition was dismissed, but the Supreme Court reversed. On remand, Appellant filed a motion for default judgment. The court of appeals denied both Appellant's motion for default judgment and his petition for a writ of mandamus. The Supreme Court affirmed and awarded statutory damages, holding that Appellant had prevailed on his claims to the extent the law allowed. View "State ex rel. Ware v. Parikh" on Justia Law

The Supreme Court held that indefinite sentencing under the "Reagan Tokes Law," which became effective in March 2019 and requires that for certain felony offenses a sentencing court impose on the offender an indefinite sentence consisting of a minimum and a maximum prison term, is not unconstitutional.The two appellants in this case - Christopher Hacker and Danan Simmons - were both subject to sentencing under the Reagan Tokes Law. On appeal, Appellants argued that Ohio Rev. Code 2967.271, which allows the Ohio Department of Rehabilitation and Correction to maintain an offender's incarceration beyond the minimum prison term imposed by a trial court, violates the separation of powers doctrine, procedural due process, and the right to a jury trial. The Supreme Court disagreed and affirmed, holding that Appellants failed to rebut the Reagan Tokes Law's presumption of constitutionality in their facial challenge. View "State v. Hacker" on Justia Law