Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the conviction and death sentence of Appellant, who murdered his mother, but reversed an aggravated robbery charge against him that was used as one of three specifications supporting the prosecution’s effort to seek the death penalty.The Supreme Court held (1) the trial court did not err in overruling Defendant’s motion to suppress; (2) no prejudicial error occurred during jury selection; (3) the trial court erred in admitting certain other acts evidence, but the errors were harmless; (4) the prosecutor did not commit misconduct during closing argument; (5) Defendant’s sentence was appropriate; (6) any error on the part of defense counsel during the penalty phase was harmless; (7) cumulative errors did not render Defendant’s trial unfair; and (8) the evidence failed to support the finding that Defendant “deprived” the victim of property or that Defendant’s “purpose” was to deprive the victim of the property at issue. View "State v. Tench" on Justia Law

The Supreme Court granted in part and denied in part the writ of mandamus requested by Relators to compel the Ohio Department of Rehabilitation & Correction (DRC) to release records related to DRC’s acquisition and supply of lethal-injection drugs, holding that Relators had a clear legal right to access certain sealed records with protected information redacted but that other information was exempt from public disclosure.At issue was sealed records identified in DRC’s Exhibit 7 log and Exhibit 8 log. The Supreme Court held (1) Relators had a clear legal right to access the sealed records in the Exhibit 7 log with only protected information redacted that could identify an entity requesting confidentiality under Ohio Rev. Code 2949.221; (2) because one letter in Exhibit 7 contained protected information that was inextricably intertwined with nonprotected information, it was exempt from disclosure; and (3) Relators failed to establish a clear legal right to compel DRC to produce the sealed records identified in the Exhibit 8 log, which were created or received by DRC after the date of Relators’ request. View "State ex rel. Hogan Lovells U.S., LLP v. Department of Rehabilitation & Correction" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant’s conviction and discharging him from further prosecution after the trial court accepted Defendant’s plea of no contest to a charge of cruelty to animals and finding Defendant guilty but neglecting to ask for an explanation of the circumstances, holding that the Double Jeopardy Clause did not bar Defendant’s retrial.On appeal, Defendant argued that the trial court erred by failing to obtain an explanation of the circumstances before finding him guilty. The court of appeals agreed, reversed Defendant’s conviction and, reasoning that the reversal was based on insufficient evidence, concluded that jeopardy had attached and barred further proceedings against Defendant. The Supreme Court reversed, holding (1) the reversal of Defendant’s conviction was not based on insufficiency of the evidence, but, rather, on a procedural error; and (2) therefore, the double jeopardy protection did not bar Defendant’s retrial. View "Girard v. Giordano" on Justia Law

The Supreme Court denied Respondent’s motion to dismiss Relator’s original action in mandamus and issued an alternative writ, holding that, although Relator was an inmate who had filed a civil action against a state employee and Relator did not attach an affidavit of prior civil actions to his complaint, Respondent was not entitled to have the complaint dismissed.Relator, an inmate at the Southern Ohio Correction Facility, alleged that he submitted a public-records request to Respondent, the public-records custodian for the facility, but never received the requested documents. Relator filed a complaint for a writ of mandamus asking the Supreme Court to compel Respondent to provide him the requested documents. Respondent moved to dismiss the complaint based on Relator’s failure to comply with the filing requirements set forth in Ohio Rev. Code 2969.25. The Supreme Court held (1) section 2969.25 does not apply to this matter, and because it does not apply, Respondent’s motion to dismiss is denied; and (2) Relator is entitled to an alternative writ. View "State ex rel. McDougald v. Greene" on Justia Law

The Supreme Court reversed the judgment of the Court of Appeals affirming the trial court’s suppression of 150 individually wrapped pieces of marijuana-infused candy contained in two sealed Priority Mail envelopes located inside an open box on the back seat of Defendant’s vehicle during a traffic stop, holding that the search of the envelopes and the duration of the traffic stop were not in violation of Defendant’s constitutional rights.Specifically, the Court held that after finding marijuana and other drug paraphernalia in Defendant’s car, the arresting officer had probable cause to open the envelopes and had the right to detain Defendant for as long as reasonably necessary to complete the search of the vehicle. View "State v. Vega" on Justia Law

The Supreme Court affirmed Defendant’s conviction of aggravated murder and sentence of death, imposed after the case was remanded for resentencing, holding that none of Defendant’s propositions of law on appeal warranted reversal.Specifically, the Court held (1) the trial court did not err when it excluded testimony that Defendant sought to present as additional mitigating evidence in the time between the two sentencing hearings; (2) the trial court did not violate Defendant’s due process rights by refusing to empanel a new jury for the resentencing hearing; (3) trial counsel did not provide ineffective assistance at the resentencing hearing; (4) Defendant was not denied the opportunity to deny or explain evidence at the resentencing hearing; and (5) Defendant’s sentence of death was appropriate and proportional. View "State v. Goff" on Justia Law

The Supreme Court reversed the judgment of the court of appeals concluding that an order appointing a guardian ad litem (GAL) for an adult is not a final, appealable order under Ohio Rev. Code 2505.02(B) and vacated the trial court’s order appointing a GAL to act on Appellant’s behalf in her divorce case.The court of common pleas, domestic relations division, issued an order appointing a GAL to represent Appellant in her divorce case without providing her with prior notice or an opportunity to be heard on the issue. The Supreme Court remanded the case to the trial court for further proceedings, holding (1) because the order was issued during a special proceeding and affects a substantial right and because Appellant will not be provided adequate relief if she is not permitted immediately to appeal the order, the order is a final, appealable order under section 2505.02(B)(2); and (2) the order violated Appellant’s due process rights. View "Thomasson v. Thomasson" on Justia Law

At issue was whether the trial court had authority to enjoin the state from enforcing new statutes as punishment for contempt of court.The court of common pleas found the state to be in contempt of a court order that permanently enjoined the state from enforcing several statutes that the court had declared unconstitutional. The contempt finding was based on the General Assembly’s enactment of new statutes that reduced funding to cities that were not acting in compliance with the statutes that were previously declared unconstitutional. As punishment for the contempt, the state was enjoined from enforcing the new laws. The court of appeals affirmed. The Supreme Court reversed the judgment of the court of appeals, vacated the order of contempt, and dissolved the injunction against enforcing the spending provisions enacted by 2015 Am.Sub.H.B. No. 64 (H.B. 64), holding that the trial court lacked authority to enjoin enforcement of the spending provisions enacted in H.B. 64 because the statutes had not been declared unconstitutional. View "Toledo v. State" on Justia Law

The Supreme Court affirmed Defendant’s convictions of aggravated murder with a death specification, felony-murder, kidnapping, aggravated robbery, aggravated burglary, and other crimes and the trial court’s imposition of the death penalty.On appeal, Defendant presented eighteen propositions of law. The Supreme Court examined each of Defendant’s claims and found that none had merit. Accordingly, the Court affirmed Defendant’s convictions and sentence of death, holding that there was no reversible error committed in the proceedings below and that Defendant was not entitled to relief. View "State v. Myers" on Justia Law

The Supreme Court held that Ohio’s death-penalty scheme does not violate the right to a trial by jury as guaranteed by the Sixth Amendment to the United States Constitution.Appellant was sentenced to death. The court of appeals remanded the case to the trial court for a new penalty-phase trial. On remand, Appellant moved to dismiss the capital specification from his indictment, arguing that Ohio’s death-penalty scheme is unconstitutional under the United States Supreme Court’s decision in Hurst v. Florida, __ U.S. __ (2016). Hurst invalidated Florida’s former capital-sentencing scheme because it “required the judge alone to find the existence of an aggravating circumstance.” The trial court granted the motion. The Supreme Court affirmed, holding that because Ohio law requires the critical jury findings that were not required by the law at issue in Hurst, Ohio’s death-penalty scheme does not violate a defendant’s right to a trial by jury as guaranteed by the Sixth Amendment. View "State v. Mason" on Justia Law