Justia Civil Rights Opinion Summaries

In 2003, Defendant pleaded guilty to aggravation with a firearm specification. The State and Defendant later agreed that Defendant could withdraw his guilty plea and instead plead guilty to aggravated robbery without a firearm specification and to one count of an attempt to have weapons while under a disability. The new agreement decreased Defendant’s sentence by six months. In 2009, Defendant pled guilty to attempted felonious assault. The trial court sentenced Defendant to a term of imprisonment, to run consecutively to the sentence from the 2003 case. Defendant subsequently sought a writ of habeas corpus, arguing that his 2007 plea and resentencing were void and he was therefore entitled to immediate release. The appellate court denied the writ, concluding that Defendant had already unsuccessfully pursued an adequate legal remedy to challenge his 2007 conviction and could not use habeas corpus to try again. The Court of Appeals affirmed, holding that Defendant’s claim was barred by res judicata. View "Smith v. Buchanan" on Justia Law

Appellant pleaded guilty a violation of Ohio’s RICO statute and a predicate offense of trafficking in marijuana. The trial court imposed a six-year sentence for the RICO offense and an eight-year sentence for the trafficking offense, to be served consecutively. On appeal, Appellant asserted that the trial court’s imposition of consecutive prison sentences violated the prohibition against double jeopardy. The court of appeals affirmed Appellant’s separate sentences. Appellant appealed, arguing that the appellate court was required to apply the standard set forth in State v. Johnson in deciding whether the imposition of multiple convictions and sentences for a RICO offense and one or more of its predicate felonies violated the Allied Offenses statute and his rights under the double jeopardy clauses of the state and federal Constitutions. The Supreme Court affirmed, holding that State v. Johnson is not applicable to a RICO violation and that a RICO offense does not merge with its predicate offenses for purposes of sentencing. View "State v. Miranda" on Justia Law

In September 1991, Appellant was convicted in federal court of criminal offenses and sentenced to federal prison. Meanwhile, in January 1991, the Crawford County Sheriff’s Department served a warrant on Appellant for his arrest after his indictment in Crawford County. Appellant was arraigned in Crawford County then returned to federal custody. In April 1992, Appellant was returned to Crawford County, tried in a jury trial, and convicted of criminal offenses. On appeal, Appellant argued that his speedy-trial rights were violated under the Interstate Agreement on Detainers (IAD). The court of appeals affirmed on appeal and dismissed Appellant’s subsequent petition for a writ of habeas corpus. The Supreme Court affirmed the court of appeals’ denial of a writ of habeas corpus, holding (1) because Appellant was not returned to federal custody after April 1992 until his state court trial had been held, no violation of the IAD occurred; and (2) the court of appeal’s determination on appeal that no violation of the IAD occurred was res judicata as to Appellant’s claims in this case. View "State ex rel. Dye v. Bradshaw" on Justia Law

After a car accident involving David Fraley and Timothy Oeding, Oeding’s insurer (“Auto-Owners”) placed an investigative hold on Fraley’s truck for several months. Fraley filed a negligence action against Oeding’s estate, Oeding’s employer (“J&R”), and Auto-Owners, alleging, among other things, that Auto-Owners’ investigatory hold caused Fraley intangible economic loss due to the loss of use of the truck. The trial court dismissed the complaint, holding (1) the court could not exercise personal jurisdiction over Oeding and J&R solely because their insurer did business in Ohio, and (2) Fraley was not entitled to maintain a direct action against Auto-Owners because he had not obtained a judgment against Auto-Owners’ insureds. The court of appeals reversed, concluding that the trial court erred in its determination that it lacked personal jurisdiction over Oeding and J&R because Auto-Owners’ investigatory hold and its communication with Fraley brought Auto-Owners, and by extension J&R and Oeding, within Ohio’s long-arm statute. The Supreme Court reversed, holding that an Ohio court may not impute an insurance company’s conduct to its nonresident insured for purposes of establishing personal jurisdiction over the insured. View "Fraley v. Estate of Oeding" on Justia Law

Defendant was charged with felony domestic violence, which contained an allegation that Defendant had been previously convicted of two offenses of domestic violence. After a jury trial, Defendant was convicted of domestic violence as charged. The appellate court reversed Defendant’s conviction, determining that the state failed to establish the necessary element of Defendant’s prior domestic violence convictions. The Supreme Court reversed the judgment of the appellate court and reinstated the judgment of the trial court, holding that because, during trial, the defense stipulated to the authenticity of Defendant’s two prior first degree misdemeanor domestic violence convictions, the state did properly prove the instant conviction. View "State v. Tate" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of sexually-related crimes arising from incidents involving underage boys, including rape and gross sexual imposition. Defendant appealed, arguing, among other things, that his confrontation rights were violated when he was not allowed to cross-examine Mark Losko with the Bureau of Criminal Identification and Investigation (BCI) because Losko was not called to testify at trial regarding the DNA profile he created for Defendant and the alleged victims. The court of appeals affirmed the judgment of the trial court, concluding that because Losko's report contained only raw data and because Kristen Slaper, a BCI forensic analyst, testified and was cross-examined regarding her own report linking Defendant to the incriminating DNA evidence, Defendant's Sixth Amendment rights had not been violated. The Supreme Court affirmed, holding (1) when a defendant has stipulated to the admissibility and content of a nontestifying analyst's scientific report, the testimony of a witness who relied on that report does not violate the defendant's right to confrontation; and (2) because Defendant stipulated to Losko's report, he waived any later Confrontation Clause challenge to the use of the report by other witnesses. View "State v. Keck" on Justia Law

Defendant was convicted of failure to comply with a police officer and obstruction of official business. The trial court imposed separate sentences for the two offenses. Defendant appealed, arguing that the offenses should have merged at sentencing as allied offenses of similar import under Ohio Rev. Code 2941.25. The appellate court remanded for a determination as to whether the offenses were allied offenses under State v. Johnson, which instructs courts that a defendant's conduct "must be considered" when determining whether multiple offenses merge at sentencing pursuant to section 2941.25. The trial court determined that the offenses were not allied offenses of similar import and imposed separate prison terms for the two offenses. The court of appeals reversed, concluding that Defendant's sentences merged under Johnson because they were based on the same conduct. The Supreme Court reversed, holding (1) when deciding whether to merge multiple offenses at sentencing pursuant to section 2941.25, a court must review the entire record to determine whether the offenses were committed separately or with a separate animus; and (2) the court of appeals erred by relying on Johnson for the proposition that a court may consider a defendant's conduct only as it was described by the state's theory at trial. View "State v. Washington" on Justia Law

Ramona Whitley and Debra Jones, teachers at a preschool day care, questioned three-year-old L.P. about an eye injury and marks on his face upon his arrival at the preschool. Whitley reported suspected child abuse after L.P. identified Defendant as responsible for his injuries. A grand jury subsequently indicted Defendant of several counts of felonious assault, endangering children, and domestic violence. After a jury trial, Defendant was convicted of all charges except one felonious assault count. The court of appeals reversed Defendant's convictions and remanded for a new trial, holding that the trial court abused its discretion by permitting the preschool teachers to testify regarding L.P.'s statements in violation of the Confrontation Clause. The Supreme Court affirmed, holding (1) statements elicited from a child by a teacher in the absence of an ongoing emergency and for the primary purpose of gathering information of criminal conduct and identifying the alleged perpetrator of suspected child abuse are testimonial in nature; and (2) therefore, the admission of L.P.'s statements violated Defendant's right to confrontation. View "State v. Clark" on Justia Law

Petitioner pled guilty to various drug and weapons offenses and was sentenced to five years' imprisonment. On February 17, the trial court issued an order granting 1,530 days of jail-time credit. On February 18, however, the court set aside the February 17 entry on the grounds that it had been inadvertent. Petitioner was ultimately resentenced to concurrent five-year sentences for the remaining offenses with 964 days of jail-time credit. Petitioner subsequently made the February 17 and February 18 entries the subject of numerous proceedings, including a habeas action, in which he claimed that he was entitled to the jail-time credit awarded him in the February 17 entry. Petitioner then filed this petition for a writ of habeas corpus, making the same claim advanced in his earlier habeas petition. The Supreme Court dismissed the habeas action, holding (1) Petitioner had alternate remedies in the ordinary course of law to pursue relief on his claim; (2) res judicata barred Petitioner's claim; and (3) Petitioner's claim was invalid on the merits. View "Pruitt v. Cook" on Justia Law

Defendant was convicted of two counts each of aggravated murder, attempted murder, and aggravated robbery. The trial court imposed capital punishment for aggravated murder an an aggregate term of twenty-six years' imprisonment for the noncapital offenses. The Supreme Court (1) reversed one of Defendant's aggravated murder convictions, the specifications related to that count, and the specification associated with the other aggravated murder charge because each of these counts and specifications required proof that Defendant was under detention at the time of the murder, and the original sentencing entry that placed Defendant under detention was void; and (2) affirmed the remaining convictions, the imposition of capital punishment in the other aggravated murder count, and the imposition of consecutive terms of imprisonment on the noncapital offense convictions. View "State v. Wesson" on Justia Law