Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals determining that Ohio Rev. Code 2152.84(A)(2)(b) was fundamentally unfair as applied to D.R., the juvenile in this case, and thus violated his right to procedural due process, holding that the court of appeals did not err.D.R. was adjudicated delinquent for sexually assaulting his friend when he was sixteen years old. The juvenile court suspended D.R.'s commitment and placed him on probation with conditions. The court classified D.R. as a Tier I offender and notified him that he had a duty to register as a sex offender. At the end of D.R.'s disposition, the magistrate terminated D.R.'s probation but continued his Tier I classification on the grounds that it lacked the statutory authority the terminate the classification. The court of appeals reversed. The Supreme Court affirmed, holding that the statute was fundamentally unfair as applied to D.R. and violated due process. View "In re D.R." on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the trial court to deny Appellant's petition for postconviction relief, holding that, under the circumstances of this case, the court abused its discretion in denying Appellant's petition for postconviction relief.In 2016, Appellant was found guilty of aggravated murder, gross abuse of a corpse, and tampering with evidence. The trial court sentenced Appellant to life in prison without the possibility of parole for the aggravated murder. Appellant later filed a petition for postconviction relief arguing that her trial counsel provided ineffective assistance in failing to present evidence about neonaticide, as it is currently understood, as a mitigating factor. The trial court denied the petition, and the court of appeals affirmed. The Supreme Court reversed, holding that the trial court's decision denying Appellant's postconviction petition was unreasonable and arbitrary and not based on competent and credible evidence. View "State v. Weaver" on Justia Law

The Supreme Court affirmed the decision of the court of appeals upholding that decision of the trial court to deny Defendant's motion to suppress evidence discovered after a traffic stop, holding that there was no error.After executing the traffic stop at issue, a law enforcement officer ordered Defendant to step out of the car and opened the door for him to do so. Another officer later looked through the open door and spotted a marijuana cigarette on the floor. A subsequent search of the car led to the discovery of a pistol. Defendant pleaded no contest to firearm-related charges. On appeal, Defendant challenged the denial of his motion to suppress. The court of appeals affirmed. The Supreme Court also affirmed, holding (1) the officers did not violate the Fourth Amendment by ordering Defendant to exit the car; (2) opening the door was not a search; (3) the second officer did not conduct a search; and (4) under the automobile exception to the warrant requirement, the discovery of the marijuana cigarette in plain view allowed the officers to search the car. View "State v. Jackson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the judgment of the trial court dismissing rape charges against Defendant due to prejudicial preindictment delay, holding that Defendant failed to demonstrate actual prejudice. In 2017, Defendant was indicted on a multiple-count indictment alleging that Defendant had raped the complaining witness in 2005. The trial court dismissed the charges. The court of appeals affirmed, concluding that Defendant had demonstrated actual prejudice. The Supreme Court affirmed reversed after clarifying that, in determining whether unconstitutional preindictment delay has occurred in a rape case in which consent is at issue, the relevant inquiry is whether the defendant has shown actual prejudice, holding that Defendant failed to show actual prejudice under the standard set forth in State v. Jones, 69 N.E.3d 688 (Ohio 2016). View "State v. Bourn" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the the trial court's decision ordering $1,615 in restitution for lost wages of the victim after Defendant pleaded guilty to two fifth-degree felony charges, holding that unless the loss of wages is directly and proximately caused by the offense, lost wages are not compensable as restitution.During the restitution hearing the victim testified that she was seeking restitution for lost wages relating to the wages she lost as a result of attending hearings for the criminal cases. The trial court ultimately ordered restitution for the lost wages of the victim. The court of appeals reversed. The Supreme Court affirmed, holding that the statutory meaning of restitution was not altered or expanded by Ohio Const. art. I, 10a, otherwise known as Marsy's Law, and that crime victims should receive restitution from those whose crimes that have directly and proximately caused them to suffer economic loss or detriment. View "State v. Yerkey" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's convictions and sentence for three counts of aggravated murder, six counts of aggravated robbery and other crimes and his sentence of life in prison, holding that a trial court errs in its evaluation of a defendant's lack of remorse when it considers that defendant's decision to waive allocution and remain silent at sentencing if the defendant exercised his right to a jury trial.Specifically, the Supreme Court held (1) the lower courts did not err in determining that Defendant did not waive his attorney-client privilege with regard to direct communications with his attorney; (2) even if this case presented circumstances in which the attorney-client privilege yielded to Defendant's right to confrontation, any error was not prejudicial; and (3) while the trial court erred in considering Defendant's decision to waive allocution and remain silent in determining whether he lacked remorse, the error was not prejudicial. View "State v. Brunson" on Justia Law

The Supreme Court reversed the judgment of the court of appeals affirming the decision of the juvenile court to transfer Appellant to adult court, holding that that court's decision to transfer Appellant to adult court was not supported by a preponderance of the evidence and that the juvenile court abused its discretion by relinquishing jurisdiction.After the juvenile court transferred jurisdiction over Appellant to the general division a jury found Appellant guilty of aggravated murder and murder for a killing that occurred when he was fourteen years old. The court of appeals affirmed the conviction, concluding that the juvenile court did not violate Appellant's constitutional right to due process by transferring his case to the adult court. The Supreme Court reversed, holding (1) the standard of proof applicable to discretionary-bindover proceedings is a preponderance of the evidence, and the state need not produce affirmative evidence of nonamenability; (2) a juvenile court need not consider all potential juvenile dispositions when balancing the factors weighing in favor of and against transfer; and (3) the juvenile court improperly relinquished jurisdiction in this case. View "State v. Nicholas" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated murder and his sentence of death, holding that, while error occurred in this case in the form of repetitive crime scene photos, the prosecutor's misstatements, and sentencing opinion errors, none of the errors resulted in prejudicial error.After a jury trial, Defendant was found guilty of the aggravated murders of his four-year-old daughter, C.D., and her mother, Nicole Duckson, with accompanying death-penalty specifications. The court sentenced Defendant according to the jury's recommendation of a sentence of death for the aggravated murder of C.D. The court then sentenced Defendant to life without parole for the aggravated murder of Nicole. The Supreme Court affirmed but remanded the case, holding (1) Defendant received a fair trial, and none of the errors in this case, when considered either individually or cumulatively, resulted in prejudicial error; (2) the overwhelming evidence established Defendant's guilt; and (3) the case must be remanded for the trial court to issue a nunc pro tunc entering confirming the September 14, 2019 judgment entry and the September 16, 2019 entry to the sentence that was imposed at the sentencing hearing. View "State v. Garrett" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's convictions and remanding the matter for a new trial, holding that the trial court did not violate Defendant's Sixth Amendment right to a public trial by partially limiting access to the courtroom after an altercation disrupted court proceedings.Defendant was indicted on two counts of murder. During a recess on the third day of trial, some of the people attending the trial were involved in an altercation outside the courtroom, which resulted in the court limiting attendees to only immediate family members. Defendant was subsequently found guilty of murder as a result of felonious assault. The court of appeals reversed, ruling that the trial court had committed structural error by failing to provide sufficient justification for the partial closure of the courtroom. The Supreme Court reversed, holding that a public trial violation occurred in Defendant's trial but that the error did not rise to the level of a plain error that must be corrected. View "State v. Bond" on Justia Law

The Supreme Court affirmed the decision of the court of appeals denying Appellant's petitions for postconviction relief challenging his convictions in a rape case and a jail case, holding that there was no error.After a jury trial, Appellant was convicted of rape and kidnapping. While he was being held in jail on the rape charges, Appellant and two other inmates attacked one of their cellmates. A jury found Appellant guilty of felonious assault and kidnapping for the attack. Appellant later filed petitions for postconviction relief challenging his convictions in both cases. The trial court denied relief. The Supreme Court affirmed, holding (1) postconviction claims alleging a denial of the constitutional right to effective assistance of counsel are not procedurally barred if they cannot meaningfully be reviewed without resorting to evidence outside the trial record; and (2) all of Appellant's claims were either barred by res judicata or failed to set forth a substantive claim for relief. View "State v. Blanton" on Justia Law