Justia Civil Rights Opinion Summaries

A juvenile court judge in Hamilton County, Ohio, presided over the trial of a thirteen-year-old accused of felonious assault. The judge found the juvenile not delinquent and sealed the case record under Ohio Revised Code (R.C.) 2151.356(B)(1)(d). After the juvenile was later killed, the Cincinnati Enquirer requested the trial transcript, which the judge denied, citing the statute.The Cincinnati Enquirer challenged the constitutionality of R.C. 2151.356, arguing that the Ohio Constitution's open courts provision prohibits sealing court records without an individualized determination balancing the interests of the juvenile and the public. The juvenile court judge argued that the open courts provision does not apply to juvenile delinquency proceedings, relying on precedent from the Ohio Supreme Court.The Supreme Court of Ohio reviewed the case and held that the open courts provision of the Ohio Constitution applies to juvenile delinquency proceedings. The court determined that R.C. 2151.356 is unconstitutional because it mandates the sealing of records without an individualized balancing of interests. The court granted a writ of mandamus ordering the juvenile court judge to provide access to the trial transcript and a writ of prohibition preventing the enforcement of the sealing order. View "State ex rel. Cincinnati Enquirer v. Bloom" on Justia Law

A property developer settled claims with the U.S. Department of Justice for alleged violations of the Fair Housing Act (FHA) and sought to assert a state-law claim for contribution against other companies involved in developing the properties. The developer, Epcon Communities Franchising, L.L.C., alleged that the franchisees, including Wilcox Development Group, L.L.C., failed to comply with the FHA in their construction and design of certain properties.The trial court dismissed the case, not on the grounds argued by Wilcox, but on the theory that if a state-law cause of action for contribution existed, it was preempted by federal law. The Tenth District Court of Appeals affirmed this decision, and Epcon appealed the preemption issue to the Supreme Court of Ohio.The Supreme Court of Ohio reviewed the case and determined that the trial court erred in deciding the case on the basis of federal preemption. The court emphasized principles of judicial restraint, noting that no party had argued for federal preemption and that courts should avoid deciding constitutional questions unless necessary. The court also highlighted that the preemption issue was hypothetical and should not have been addressed without first determining whether a state-law contribution claim was available.The Supreme Court of Ohio reversed the judgments of the lower courts and remanded the case to the trial court to consider whether the facts alleged present a claim for relief under Ohio law. The court did not address the preemption issue, as it was not properly presented by the parties and was unnecessary to resolve at this stage. View "Epcon Communities Franchising, L.L.C. v. Wilcox Dev. Group, L.L.C." on Justia Law

An inmate at the Marion Correctional Institution, Willard McCarley, submitted a statement alleging sexual assault by a prison doctor. The institutional investigator found the allegation to be false and issued a conduct report accusing McCarley of violating Rule 27, which prohibits giving false information to departmental employees. The Rules Infraction Board (RIB) found McCarley guilty and placed him in disciplinary control for 14 days. McCarley appealed the decision to the warden and the Ohio Department of Rehabilitation and Correction’s (DRC) chief legal counsel, both of whom affirmed the RIB’s decision.McCarley then filed a mandamus action in the Tenth District Court of Appeals, seeking to compel the DRC to vacate the RIB’s decision. He argued that there was no evidence to support the finding that he lied. The court referred the matter to a magistrate, who recommended granting the DRC’s motion for judgment on the pleadings, stating that McCarley failed to show a clear legal right to the relief sought or a clear legal duty on the part of the DRC. The court of appeals initially remanded the case to the magistrate to address the sufficiency of evidence but ultimately adopted the magistrate’s recommendation and denied the writ.The Supreme Court of Ohio reviewed the case and affirmed the Tenth District’s judgment. The court held that McCarley did not demonstrate that the RIB’s guilty finding imposed an atypical and significant hardship or affected the duration of his confinement, which are necessary to establish a constitutionally protected liberty interest. Additionally, the court found that the RIB’s decision was supported by “some evidence,” specifically the “unfounded” finding of the PREA investigation. Therefore, McCarley was not entitled to mandamus relief, and the DRC was entitled to judgment as a matter of law. View "State ex rel. McCarley v. Dept. of Rehab. & Corr." on Justia Law

A mother, K.G., gave birth to twins in September 2020. Due to concerns about her mental health and ability to care for the children, Muskingum County Adult and Child Protective Services (the agency) took emergency temporary custody of the children. The children were placed with their maternal aunt. The juvenile court adjudicated the children as dependent and continued the agency's temporary custody. K.G. was required to undergo a psychological evaluation, which revealed several mental health conditions that could impair her parenting abilities.The juvenile court later transferred temporary legal custody to the maternal aunt, with the agency maintaining protective supervision. The agency then moved for the maternal aunt to be granted legal custody and for the agency's supervision to be terminated. At the hearing, the agency presented a psychological report by Dr. Wolfgang, which K.G. objected to, arguing she should be able to cross-examine the psychologist. The juvenile court admitted the report and granted legal custody to the maternal aunt.The Fifth District Court of Appeals reversed the juvenile court's decision, holding that K.G.'s due process rights were violated because she was not able to cross-examine Dr. Wolfgang. The agency appealed to the Supreme Court of Ohio.The Supreme Court of Ohio reversed the appellate court's decision, holding that the juvenile court was permitted to consider the psychologist’s report under the statutory scheme governing legal-custody proceedings. The court found that K.G. was not denied an opportunity to cross-examine Dr. Wolfgang and that her due process rights were not violated. The case was remanded to the appellate court for consideration of K.G.'s remaining assignment of error. View "In re R.G.M." on Justia Law

In April 2012, Arnold Black was arrested during a traffic stop by East Cleveland police officers without any legitimate reason. Detective Randy Hicks violently assaulted Black and detained him in a storage room for four days. Black sued Hicks, Chief Ralph Spotts, and the City of East Cleveland for his injuries. In August 2019, a jury awarded Black $20 million in compensatory damages and $15 million in punitive damages against Hicks and Spotts each. The trial court also awarded Black $5.2 million in prejudgment interest.The City of East Cleveland and Spotts appealed to the Eighth District Court of Appeals, which affirmed the trial court’s judgment. The Ohio Supreme Court declined jurisdiction over their discretionary appeal, and the United States Supreme Court denied the city’s petition for a writ of certiorari. Despite these rulings, the city failed to satisfy the judgment or take steps to appropriate the necessary funds.The Supreme Court of Ohio reviewed the case and granted Black’s request for a writ of mandamus. The court held that Black had a clear legal right to enforcement of the civil judgment and that the city had a legal duty to pay the judgment, including pre- and postjudgment interest. The court ordered the city to satisfy the judgment or take the necessary steps to appropriate the funds as described in R.C. 2744.06(A). The court rejected the city’s argument that a pending trial-court motion could reduce the amount owed, noting that Black had established the exact amount of money owed with sufficient evidence. View "State ex rel. Black v. Cleveland" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition ordering the trial court to vacate his criminal sentence, holding that Appellant was not entitled to a writ of mandamus or prohibition.Appellant was convicted of escape, retaliation, and other offenses and sentenced to 26.5 years in prison. Appellant later brought the current action seeking writs of prohibition and mandamus ordering the trial court to vacate his sentencing entries and to grant any other relief to which he was "entitled." The court of appeals dismissed the complaint for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law through direct appeal to raise his claim that the Sixth Amendment requires that a defendant be expressly informed of his right to counsel at each critical stage of the proceeding and that the trial court's failure to do so in his case rendered his sentence void. View "State ex rel. Rarden v. Butler County Common Pleas Court" on Justia Law

In this case concerning how an Ohio prisoner is to enforce his constitutional right to a speedy trial on an untried indictment the Supreme Court held that a prisoner satisfies the "causes to be delivered" requirement of Ohio Rev. Code 2941.401 when he delivers the written notice and the request to the warden where he is imprisoned, even if the warden fails to deliver the notice and the request to the prosecuting attorney or the appropriate court.Appellant, who was indicted on counts of aggravated robbery and robbery, moved to dismiss the indictment on speedy-trial grounds. The trial court granted the motion, concluding that Appellant had strictly complied with section 2941.401 when he provided written notice of his place of imprisonment and a request for a final disposition and that the 180-day speedy trial time was not tolled by the warden's failure to comply with his duty to send out Appellant's written notices and requests to the prosecuting attorney or the appropriate court. The court of appeals reversed, concluding that Appellant had not strictly complied with the requirements of the statute. The Supreme Court reversed, holding that Appellant caused to be delivered his written notice and request for final disposition under the statute when he provided them to the warden. View "State v. Williams" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's convictions for felony charges stemming from an inventory search of an impounded truck that Defendant was driving when he was pulled over by a law enforcement officer, holding that the search was reasonable and lawful under the Fourth Amendment.Law enforcement performed an inventory search as to the truck at issue and found a handgun in the truck's right door panel. After Defendant unsuccessfully moved to suppress the evidence of the gun the trial court found him guilty. The court of appeals reversed, holding that the search was not reasonable under the Fourth Amendment because the state's evidence was insufficient. The Supreme Court reversed, holding that the inventory search was lawful. View "State v. Toran" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting summary judgment in favor of the Hocking County Common Pleas Court and Judge Dale Crawford in Appellant's action for writs of mandamus and prohibition, holding that the court of appeals correctly determined that the doctrine of res judicata barred Appellant's claims.Appellant was found guilty of assaulting a peace officer. The court of appeals affirmed. About seven years later, Appellant filed a complaint for writs of mandamus and prohibition alleging that the trial court deprived her of her constitutional right to counsel and lacked jurisdiction to hold the sentencing hearing. The court of appeals concluded that the doctrine of res judicata barred Appellant's claims. The Supreme Court affirmed, holding that the court of appeals correctly determined that res judicata barred this mandamus and prohibition action. View "State ex rel. Ogle v. Hocking County Common Pleas Court" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing this complaint brought by Appellant requesting a writ of mandamus to compel the City of Mentor to commence appropriation proceedings for an alleged taking of Appellant's property, holding that the court of appeals did not err in granting the City's motion to dismiss.Appellant brought this complaint alleging that the decision of the City to deny a permit that would allow him to place a houseboat on a pond that he owned constituted a taking of his property. The court of appeals granted the City's motion to dismiss for failure to state a claim upon which relief could be granted and for lack of subject-matter jurisdiction, holding (1) Appellant had an adequate remedy in the ordinary course of the law and was not entitled to a writ of mandamus to compel the City to commence appropriation proceedings; and (2) the court of appeals lacked subject-matter jurisdiction over Appellant's remaining claims. View "State ex rel. Duncan v. Mentor" on Justia Law