Justia Civil Rights Opinion Summaries

Articles Posted in Supreme Court of Ohio
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The Supreme Court declared the congressional-district plan passed by the General Assembly invalid, holding that the General Assembly did not comply with Ohio Const. art. XIX, 1(C)(3)(a) and (b) in passing the plan and that a new congressional-district plan must be passed the complies in full with Article XIX and is not dictated by partisan considerations.At issue was 2021 Sub.S.B. No. 258, which was passed by a simple majority and signed into law by Governor Mike DeWine on November 20, 2021. The bill resulted in districts in which undue political bias was at least, if not more, likely to favor Republican candidates than the 2011 reapportionment that impelled Ohio's constitutional reforms. Petitioners argued that the congressional-district plan violated Article XIX, Section 1(C)(3)(a). The Supreme Court held that the congressional-district plan was invalid in its entirety because it unduly favored the Republican Party and disfavored the Democratic Party and because it unduly split three counties, in violation of Article XIX, Section 1(C)(3)(b). View "Adams v. DeWine" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition against Appellees - Judge Dale A. Crawford and the Hocking County Common Pleas Court - but affirmed the denial of her motion for disqualification of attorney Randall L. Lambert, holding that the court of appeals erred in part.Appellant was found guilty of assaulting a police officer. At a sentencing hearing at which Appellant appeared without counsel, Appellant refused to sign a waiver-of-counsel form. Judge Crawford conducted the sentencing hearing, at the end of which he imposed a six-month sentence in the county jail and ordered Defendant to pay a fine, restitution, and court costs. Appellant filed a complaint for writs of mandamus and prohibition alleging that Judge Crawford lacked jurisdiction to hold the sentencing hearing because she had not waived her right to counsel. The court of appeals dismissed the complaint and denied the motion to disqualify Lambert. The Supreme Court reversed in part, holding that Appellant stated a colorable claim that Judge Crawford violated her Sixth Amendment rights when he ordered her to not communicate with any lawyer and then sentenced her and that this error rendered the sentencing entry void. View "State ex rel. Ogle v. Hocking County Common Pleas Court" on Justia Law

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The Supreme Court held that neither a showing of exigent circumstances nor a showing of the impracticability of obtaining an arrest warrant is necessary to sustain the constitutionality of a warrantless arrest under either the Ohio Constitution or the United States Constitution.Defendant was convicted of multiple drug offenses. On appeal, Defendant challenged the trial court's denial of his motion to suppress, arguing that his arrest was unlawful because there were no exigent circumstances to justify a warrantless arrest. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a warrantless arrest based on probable cause and conducted in public is reasonable under the Fourth Amendment; (2) neither exigent circumstances nor the impracticability of obtaining a warrant is required to justify a warrantless felony arrest that is supported by probable cause and that is conducted in public; and (3) the arrest in this case was constitutionally valid. View "State v. Jordan" on Justia Law

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The Supreme Court held that a tax imposed solely upon a small number of billboard operators is a discriminatory tax that violates the rights to freedom of speech and a free press protected by the First Amendment to the United States Constitution.The City of Cincinnati imposed a tax on outdoor advertising signs, but through definitions and exemptions within the city's municipal code, the tax burdens feel predominantly on two billboard operators only. The two billboard operators (Appellants) sought a declaration that the tax violated their constitutional rights to free speech and a free press and requesting an injunction against the tax's enforcement. The trial court permanently enjoined the City from enforcing the tax. The court of appeals reversed in part. The Supreme Court reversed and reinstated the injunction, holding that the billboard tax did not survive strict scrutiny and therefore impermissibly infringed on Appellants' rights to free speech and a free press. View "Lamar Advantage GP Co. v. City of Cincinnati" on Justia Law

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The Supreme Court vacated Defendant's convictions of murder with capital specifications, aggravated burglary, kidnapping, and abuse of a corpse, holding that because the trial court accepted Defendant's guilty plea without first strictly complying with Crim.R. 11(C)(2)(c), Defendant's guilty plea was invalid.Specifically, the Supreme Court held that the trial court failed strictly to comply with the requirements for a valid plea colloquy under Crim.R. 11(C)(2)(c), and neither the prosecutor nor defense counsel brought the omitted constitutional rights to the court's attention at the time of the initial plea colloquy. Because this inattention was impermissible, especially in a case where a potential death sentence was at issue, the Supreme Court vacated Defendant's convictions and sentences and remanded the cause to the common pleas court for new proceedings. View "State v. Brinkman" on Justia Law

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The Supreme Court affirmed Defendant's convictions of aggravated murder with an escaping-detection specification, kidnapping, felonious assault, possessing criminal tools, tampering with evidence, and having weapons while under a disability and Defendant's sentence of death, holding that there was no error in proceedings below.Specifically, the Supreme Court held (1) the State proved beyond a reasonable doubt that Defendant committed the offenses of aggravated murder and kidnapping; (2) the trial court did not deny Defendant's right to a fair trial by denying his motion for a new venire; (3) trial counsel did not provide ineffective assistance; (4) the trial court did not err in admitting evidence of other crimes, wrongs, or acts; (5) there was no error in the sentencing opinion; and (6) there was no other error in Defendant's sentencing. View "State v. Worley" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals upholding the order of the municipal court granting Defendant's motion to suppress, holding that the police officer's investigatory stop of Defendant was reasonable and thus did not violate the Fourth Amendment.At issue was whether the officer had reasonable suspicion to briefly detain Defendant in order to confirm or dispel an unidentified witness's claim that Defendant was operating a motor vehicle while intoxicated. The trial court granted Defendant's motion to suppress. The court of appeals affirmed, holding that the officer lacked the reasonable suspicion necessary to effectuate a lawful investigatory stop because the anonymous tip lacked sufficient indicia of reliability and because there was no evidence of erratic driving by Defendant prior to the stop. The Supreme Court reversed, holding that the officer had reasonable suspicion to investigate whether Defendant was driving while drunk based on the unidentified customer's tip and the officer's own partial corroboration of that tip. View "State v. Tidwell" on Justia Law

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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