Justia Civil Rights Opinion Summaries

Articles Posted in Supreme Court of Ohio
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The Supreme Court affirmed the decision of the Board of Tax Appeals (BTA) affirming the City of Cleveland's taxation of Hazel Willacy's stock-option income that she realized in 2016, holding that Willacy's propositions of law lacked merit.Willacy earned the disputed stock options in 2007 from her former employer while she was working in Cleveland. In 2009, Willacy retired and moved to Florida without having exercised any of the options. In 2014 and 2015, Willacy exercised the majority of the options and immediately resold the shares. In 2016, Willacy exercised the remaining options. Her former employer withheld her municipal-income-tax obligation and paid it to Cleveland. Willacy sought a refund on the grounds that she did not live or work in Cleveland. The refund was denied, and the BTA affirmed the denial. The Supreme Court affirmed, holding that Cleveland's taxation of Willacy's 2016 compensation was required under municipal law and did not violate her due process rights under either the United States or Ohio constitutions. View "Willacy v. Cleveland Board of Income Tax Review" on Justia Law

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The Supreme Court reversed the court of appeals' decision reversing Defendant-doctor's convictions on the ground that the trial court should have granted Defendant's motion to suppress incriminating answers he gave during a medical board investigation, holding that the State may use incriminating answers given by a doctor during a medical board investigation in a subsequent criminal prosecution of the doctor.Defendant was convicted of three third-degree misdemeanor counts of sexual imposition. The court of appeals reversed the denial of Defendant's motion to suppress statements he had made to the medical board investigator as having been illegally compelled in violation of the Fifth Amendment. The Supreme Court reversed, holding (1) a medical license is a property right, the threatened loss of which is a form of coercion that can compromise the constitutional privilege against self-incrimination; (2) for coercion to be sufficient to warrant the suppression of statements made during a medical board investigative interview, the person making the statements must subjectively believe that asserting the privilege against self-incrimination could cause the loss of the person's medical license, and that belief must be objectively reasonable; and (3) Defendant's belief that he could lose his medical license if he refused to truthfully answer questions posed by the medical-board investigator was not objectively reasonable. View "State v. Gideon" on Justia Law

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In this appeal concerning two prison sentences that Defendant received related to 133.62 grams of powder containing detectable amounts of heroin and fentanyl the Supreme Court held that the sentence violated the double jeopardy protections of the Ohio and United States Constitutions.Defendant was sentenced on a first-degree felony conviction for trafficking in 133.62 grams of heroin and was separately sentenced on a second-degree felony conviction for trafficking in 133.62 grams of fentanyl. The court of appeals upheld the sentences, concluding that the General Assembly intended to separately punish an offender for trafficking in different types of drugs. The Supreme Court reversed, vacated the sentences, and remanded the case for resentencing, holding that the imposition of two punishments for the same, singular quantity of drugs violated Defendant's constitutional double jeopardy protections. View "State v. Pendleton" on Justia Law

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The Supreme Court held that Ohio Rev. Code 2953.08(D)(3) does not preclude an appellate court from reviewing a sentence imposed by a trial court for aggravated murder when a defendant raises a constitutional claim regarding that sentence on appeal.A jury found Defendant guilty of aggravated murder and other offenses stemming from a fatal shooting when Defendant was seventeen years old. The trial court sentenced Defendant to life imprisonment with parole eligibility after thirty years for the aggravated murder offense. On appeal, Defendant argued that his sentence violated the Eighth and Fourteenth Amendments. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Ohio Rev. Code 2953.08(D)(3) does not preclude an appellate court from reviewing a sentence imposed by a trial court for aggravated murder when a defendant raises a constitutional claim regarding that sentence on appeal; and (2) consistent with this Court's decision in State v. Long, 8 N.E.3d 890 (Ohio 2014), a trial court must separately consider the youth of a juvenile offender as a mitigating factor before imposing a life sentence under Ohio Rev. Code 2929.03 even if that sentence includes eligibility for parole. View "State v. Patrick" on Justia Law

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The Supreme Court held that the failure to serve the Ohio Attorney General a declaratory judgment claim alleging an ordinance is unconstitutional at the inception of the action does not divest the trial court of its subject matter jurisdiction pursuant to Ohio Rev. Code 2721.12.The City of Cincinnati filed an action for injunctive relief against Fourth National Realty, LLC alleging that Fourth National had installed an outdoor advertising sign without obtaining the necessary permit and variance. Fourth National filed a counterclaim seeking a declaration that the City's outdoor advertising ordnances violated its constitutional right to free speech but did not serve its counterclaim until two years into the litigation. On remand, the City argued that the trial court lacked subject matter jurisdiction because Fourth National had not served the attorney general with notice of the pending constitutional claim at the inception of Fourth National's case. The trial court concluded that it had subject matter jurisdiction, and the court of appeals affirmed. The Supreme Court affirmed, holding that section 2721.12(A) does not require service on the attorney general at the inception of the action. View "City of Cincinnati v. Fourth National Realty, LLC" on Justia Law

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The Supreme Court held that Ohio Rev. Code 2151.352 is unconstitutionally underinclusive as applied to indigent parents facing the loss of their parental rights in probate court and that indigent parents are entitled to counsel in adoption proceedings in probate court as a matter of equal protection of the law under the Fourteenth Amendment to the United States Constitution and Ohio Const. art. I, 2.Petitioners filed petitions in the probate court to adopt Mother's two children. Mother filed a request for appointed counsel, which the probate court denied. The court of appeals affirmed the denial of Mother's request for appointed counsel, concluding that equal protection and due process guarantees are inapplicable to requests for appointed counsel in adoption causes brought by private petitioners. The Supreme Court reversed, holding that the disparate treatment between indigent parents faced with losing parental rights in a custody proceeding in juvenile court, who are entitled to appointed counsel, and indigent parents faced with losing parental rights in an adoption proceeding in probate court, who are not entitled to appointed counsel, violates equal protection guarantees. View "In re Adoption of Y.E.F." on Justia Law

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The Supreme Court held that a condition of community control imposed on Defendant that Defendant "make all reasonable efforts to avoid impregnating a woman" during his sentence was not reasonably related to the goals of community control, nor was it reasonably tailored to avoid impinging Defendant's liberty no more than necessary.Defendant was convicted of several felony counts of nonsupport of dependents. Defendant's sentence included the anti-procreation condition at issue. At issue before the Supreme Court was whether the anti-procreation prohibition impermissibly infringed upon Defendant's constitutional rights. The Supreme Court reversed, holding that the condition unnecessarily imagined upon Defendant's liberty, and therefore, the trial court must remove the anti-procreation condition but may impose other conditions that are appropriately tailored to the goals of community control. View "State v. Chapman" on Justia Law

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The Supreme Court affirmed Defendant's convictions of aggravated murder and other crimes but vacated his death sentence, holding that the aggravating circumstances that Defendant was found guilty of committing did not outweigh the mitigating factors present in the case beyond a reasonable doubt, and therefore a sentence of death was not appropriate.Defendant was found guilty of multiple offenses, including aggravated murder and three accompanying death-penalty specifications - committing the aggravated murder during an aggravated robbery, an aggravated burglary, and a kidnapping. The trial court sentenced Defendant to death. At issue before the Supreme Court was whether the felony-murder aggravating circumstances that were found by the jury outweighed the mitigating factors presented by the defense beyond a reasonable doubt. The Supreme Court held that they did not and therefore remanded the case to the trial court for resentencing consistent with Ohio Rev. Code 2929.06. View "State v. Graham" on Justia Law

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The Supreme Court affirmed Defendant's convictions for kidnapping, rape, and murder, holding that when a criminal defendant validly exercises his right to self-representation he can no longer raise claim under the Sixth Amendment to the United States Constitution that his trial counsel - standby or otherwise - was ineffective.In his criminal trial, Defendant waived his right to counsel under the Sixth Amendment and chose to represent himself. The trial court accepted Defendant's waiver and appointed standby counsel to be available to assist Defendant. On appeal, Defendant argued that the trial court violated his Sixth Amendment rights by limiting the role of his standby counsel. The court of appeals affirmed, holding that, based on the court's understanding of the typical role of standby counsel, the trial court did not improperly limit the role of standby counsel. The Supreme Court affirmed, holding that because the trial court had the discretion not to appoint standby counsel at all, the court did not abuse its discretion by appointing standby counsel with a limited role. View "State v. Hackett" on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals vacating certain sexually-violent-predator specifications that had been applied to Defendant's sentence, holding that, as applied, the specifications violated the Ex Post Facto Clause of the United States Constitution.Defendant was found guilty of numerous counts of rape, kidnapping, and related crimes involving three victims, including sexually-violent-predator specifications. The court of appeals upheld the convictions on all assignments of error except those challenging Defendant's convictions on the sexually-violent-predator specifications that attached to the crimes that Defendant committed before April 29, 2005. The court vacated the convictions on those specifications as violating the Ex Post Facto Clause. The Supreme Court affirmed, holding that the application of the current version of Ohio Rev. Code 2971.01(H)(1) to Defendant for his crimes in 2003 and 2005 violated the Ex Post Facto Clause. View "State v. Townsend" on Justia Law