Justia Civil Rights Opinion Summaries

Defendant, a police officer, was charged with one count of unlawful sexual conduct with a minor and one count of sexual battery. A bench trial resulted in Defendant’s conviction for sexual battery under Ohio Rev. Code 2907.03(A)(13), which makes peace officers strictly liable for sexual conduct with anyone under the age of eighteen when the offender is more than two years older. The appellate court reversed, concluding that section 2907.03(A)(13) violated equal protection and was facially unconstitutional. The Supreme Court affirmed, holding that the statute is an arbitrarily disparate treatment of peace officers that violates equal protection principles under the state and federal constitutions. View "State v. Mole" on Justia Law

Appellant filed two legal actions. Appellant filed a complaint in federal court alleging violations of his due process and equal protection rights. The federal district court dismissed the complaint, and Appellant appealed. Appellant also filed this original action seeking a writ of mandamus to compel an employee of JPMorgan Chase Bank to pay him a certain amount of money. The court of appeals dismissed the complaint. The Supreme Court affirmed, holding that Appellant’s claims were barred by res judicata, Appellant had an adequate remedy in the ordinary course of law, and Appellant failed to identify a clear legal right to the relief he sought. View "State ex rel. McQueen v. Weibling-Holliday" on Justia Law

Appellee was charged with rape and kidnapping. Appellee filed a motion to dismiss the indictment based on unconstitutional preindictment delay. The court of common pleas dismissed the charges, concluding that the State’s indictment of Appellee one day before the expiration of the applicable twenty-year statute of limitations prejudiced Appellee. The court of appeals affirmed, concluding that Appellee suffered actual prejudice as a result of the nearly twenty-year delay between the alleged offenses and the indictment. The Supreme Court reversed, holding that the court of appeals applied an incorrect standard in its analysis of Appellee’s preindictment-delay claim. Remanded. View "State v. Jones" on Justia Law

School Choice Ohio, Inc., a private nonprofit corporation that informs parents about educational opportunities for their children, sent a public-records request to Springfield City School District seeking information regarding students enrolled in the school in the district during the 2013-2014 academic year. Springfield denied the request based on a student-information policy it had adopted that required parental written consent before Springfield would release certain student information. School Choice filed a complaint seeking a writ of mandamus compelling Springfield to produce the requested information and to amend Springfield’s student-information policy. The Supreme Court granted in part and denied in part the complaint and ordered Springfield to provide the requested records that pertain to students whose parents had signed Springfield’s consent form and that fell within the categories of personally identifiable information identified in Springfield’s consent form, holding (1) School Choice had a clear legal right to access the personally identifiable information of Springfield’s students whose parents had consented to the release of the information; and (2) School Choice failed to establish a clear legal right to compel Springfield to amend its student-information policy. View "State ex rel. Sch. Choice Ohio, Inc. v. Cincinnati Pub. Sch. Dist." on Justia Law

A complaint was filed in juvenile court alleging that A.G. was delinquent for engaging in conduct that, if committed by an adult, would have constituted aggravated robbery and kidnapping, with firearms specifications as to each. A.G. admitted to the allegations in the complaint. The juvenile court found the allegations proved beyond a reasonable doubt and ordered that A.G. be committed to the Department of Youth Services for minimum terms of one year for each of the aggravated robbery and kidnapping adjudications. A.G. appealed, arguing that the juvenile court erred in failing to merge his adjudications for aggravated robbery and kidnapping as “allied offenses of similar import” and that his trial counsel was ineffective for failing to raise the allied-offenses issue. The Court of Appeals denied relief, concluding that the aggravated robbery and kidnapping would constituted allied offenses of similar import under Ohio Rev. Code 2941.25 if committed by an adult but that criminal statutes do not apply in juvenile delinquency proceedings. The Supreme Court reversed, holding that juvenile courts must conduct the same double-jeopardy analysis in delinquency proceedings that other courts apply in adult criminal proceedings to protect a child’s right against double jeopardy. View "In re A.G." on Justia Law

Appellant made a public-records request of the City of Avon Lake for invoices from a law firm for services rendered in connection with litigation between Appellant and the City. When the City provided redacted invoices Appellant filed a petition for a writ of mandamus in the court of appeals requesting an order compelling the City to provide unredacted invoices. The court of appeals granted a writ of mandamus compelling the City to provide Appellant with copies of the relevant billings statements with an unredacted “professional fee summary” and otherwise denied Appellant’s petition. The Supreme Court affirmed, holding that Appellant failed to demonstrate that he was entitled to extraordinary relief in mandamus. View "State ex rel. Pietrangelo v. City of Avon Lake" on Justia Law

Defendant, a juvenile, was bound over to the common pleas court and indicted on four counts of aggravated murder, among related crimes. Defendant moved to suppress statements he made during a custodial interrogation, arguing that he did not knowingly, intelligently, and voluntarily waive his Miranda rights and that his statements were not voluntary. The trial court denied Defendant’s motion to suppress. Defendant subsequently pled no contest to four counts of aggravated murder, two counts of aggravated robbery, and three counts of tampering with evidence, all with firearm specifications. The Court of Appeals affirmed, holding that where, as in this case, the interrogation of the defendant is recorded electronically, the statements made are presumed to have been made voluntarily pursuant to Ohio Rev. Code 2933.81(B). The Supreme Court reversed, holding (1) section 2933.81(B) does not affect the analysis of whether a suspect intelligently, knowingly, and voluntarily waived his Miranda rights, and therefore, the State retains the burden to prove a valid waiver; and (2) as applied to statements a juvenile makes during a custodial interrogation, the section 2933.81(B) presumption that such statements are voluntary is unconstitutional. Remanded. View "State v. Barker" on Justia Law

After a bench trial, Defendant was found guilty of domestic violence, a misdemeanor in the first-degree. During trial, the victim asserted the privilege against self-incrimination at least eight times in response to questions posed to him about Defendant’s assault. Defendant appealed, raising four claims of error. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by the trial court’s inquiry into the victim’s claim of privilege nor by the trial court’s instruction to the victim to read his prior statement during his examination; (2) Defendant failed to establish that an impermissible judicial bias deprived him of a fair trial; and (3) assuming the trial court erred in allowing the victim to read his prior statement at trial, the error was harmless beyond a reasonable doubt. View "State v. Arnold" on Justia Law

Defendant pleaded guilty to the rape and murder of his grandmother and the murder of her husband. Defendant was sentenced to death for the aggravated murders. The Supreme Court affirmed the convictions and death sentences, holding (1) the trial court did not improperly deny Defendant’s request for self-representation; (2) the trial court did not violate Defendant’s right against self-incrimination when it denied Defendant’s motion to suppress certain statements he made; (3) Defendant’s challenges to the trial court’s evidentiary rulings were unavailing; (4) Defendant’s counsel provided constitutionally effective assistance; (5) any misconduct on the part of the prosecutor was not prejudicial; (6) there were no prejudicial errors in the sentencing opinion; and (7) the imposition of the death sentences was appropriate and proportional. View "State v. Obermiller" on Justia Law

Defendant entered a no-contest plea to charges of aggravated robbery and aggravated murder with capital specifications. Defendant was sentenced to death for the murder. The Supreme Court affirmed Defendant’s convictions and death sentence, holding (1) Defendant’s constitutional challenges to Ohio’s death penalty laws were unavailing; (2) the trial court erred by denying one of seven pretrial motions Defendant filed, but in so doing, the trial court did not undermine Defendant’s right to a jury trial; (3) the trial court did not err by denying Defendant’s motion to have a copy of the prosecutor’s complete file turned over to the court for review; (4) the trial court correctly denied Defendant’s motions to suppress his confession; (5) the trial court did not err by admitting fingerprint evidence; (6) the prosecutor did not engage in impermissible misconduct; (7) Defendant received effective assistance of counsel; and (8) Defendant’s death sentence was appropriate. View "State v. Belton" on Justia Law