Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals affirming the trial court's denial of Defendant's motion to dismiss the criminal case against him based on an alleged violation of his statutory speedy-trial right, holding that the State did not violate Defendant's speedy-trial rights.The day before trial was set to begin, Defendant moved to dismiss the case base on an alleged violation of his statutory right to a speedy trial. The trial court denied the motion. Thereafter, Defendant entered a plea of no contest to a single felony count. The court of appeals affirmed. The Supreme Court affirmed, holding that there was no violation of Defendant's statutory speedy-trial rights in this case. View "State v. Belville" on Justia Law

The Supreme Court denied a writ of mandamus compelling Ohio Secretary of State Frank LaRose to allow Relator to appoint election observers to inspect the counting of votes and compelling LaRose to provide election observers with copies of all software, hardware, and source codes installed on any automatic vote-tabulating machine, holding that Relator was not entitled to the writ.Relator, an independent candidate for Ohio Secretary of State on the November 8, 2022 general-election ballot, brought this expedited election case (1) asserting that Ohio Rev. Code 3505.21, which governs the appointment of election observers, violates constitutional equal protection guarantees because it restricts certified independent candidates' ability to appoint election observers; and (2) asking that tabulating-machine software be "open or unlocked" so that observers "may inspect [the machines] to the source code level[.]" The Supreme Court denied the writ, holding that there was no basis for a writ of mandamus to issue. View "State ex rel. Maras v. LaRose" on Justia Law

The Supreme Court affirmed Defendant's conviction for aggravated murder with death specifications and her sentence of death, holding that Defendant was not entitled to relief on her allegations of error.On appeal, Defendant raised sixteen propositions of law. The Supreme Court rejected each proposition of law, holding, among other things, that (1) there was no prejudicial error in the trial court's evidentiary rulings; (2) Defendant was not entitled to relief on his ineffective assistance of counsel claims; (3) although significant mitigating factors existed, the aggravating circumstances outweighed the mitigating factors beyond a reasonable doubt; and (4) the death sentence was appropriate and proportionate. View "State v. Drain" on Justia Law

The Supreme Court reversed the judgment of the court of appeals determining that the evidence should have been suppressed in the underlying criminal case based on a statutory violation, holding that there was no violation of Defendant's Fourth Amendment rights in this case.While Defendant was serving community control, his probation officer conducted a random home-check on Defendant, searched his cell phone, and discovered child pornography. Defendant moved to suppress the uncovered evidence on the grounds that the suspicion-less search violated the Fourth Amendment. The district court denied the suppression motion. The court of appeals reversed, concluding that the search violated Ohio Rev Code 2951.02(A)'s requirement that a probation officer may conduct a search only when there are "reasonable grounds to believe" that a probationer is violating the law or conditions of control. The Supreme Court reversed, holding (1) the probation officer exceeded the scope of her authority when she searched Defendant's cell phone without reasonable grounds to believe that he had violated the law or the conditions of probation; and (2) because there was no constitutional violation, there was no basis to exclude the evidence obtained as a result of the search. View "State v. Campbell" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the order of the trial court ordering forfeiture of Appellant's 2014 Chevrolet Silverado, holding that there was no equal protection violation and that, as applied to Appellant, the vehicle forfeiture did not violate the Excessive Fines Clause of the Eighth Amendment.Appellant entered a plea of no contest to one charge of operating a vehicle while intoxicated (OVI). Because Appellant had two prior OVI convictions within the preceding ten years, his vehicle was seized pending the completion of the proceedings. After a forfeiture hearing held pursuant to Ohio Rev. Code 4503.234 the trial court ordered Appellant to forfeit his vehicle. The court of appeals affirmed. The Supreme Court affirmed, holding (1) the statutory classification contained in Ohio Rev. Code 4511.19(G)(1)(c)(v) does not violate constitutional equal protection guarantees; and (2) the forfeiture of Appellant's vehicle was not grossly disproportional and was thus not unconstitutional as applied to Appellant. View "State v. O'Malley" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that Ohio Rev. Code 4117.11(B)(7) does not violate the First Amendment, holding that the statute's prohibition on inducing or encouraging targeted picketing in connection with a labor-relations dispute violates the First Amendment.Section 4117.11(B)(7) makes it an unfair labor practice for an employee organization or public employees to "induce or encourage any individual in connection with a labor relations dispute to picket the residence or any place of private employment of any public official or representative of the public employer.” The common pleas court in this case rejected a constitutional challenge to the statute, ruling that section 4117.11(B)(7) was a valid, content-neutral time, place and manner limitation on speech. The court of appeals reversed. The Supreme Court affirmed, holding that the law was a form of expressive-activity suppression that was irreconcilable with First Amendment protections. View "Portage County Educators Ass'n for Developmental Disabilities v. State Employment Relations Bd." on Justia Law

The Supreme Court vacated Defendant's conviction for aggravated burglary, vacated the finding of guilt on count three charging Defendant with felony murder during an aggravated battery, and dismissed the death penalty specifications predicated on aggravated burglary but affirmed Defendant's remaining convictions and his death sentence, holding that there was insufficient evidence to convict Defendant of burglary.After a trial, a jury found Defendant guilty of aggravated murder and three accompanying death-penalty specifications. The trial court sentenced Defendant to death. The Supreme Court largely affirmed, holding (1) contrary to Defendant's argument on appeal, the indictment in this case was not defective; (2) there was insufficient evidence to convict Defendant of aggravated burglary; (3) no plain error occurred during the prosecutor's trial-phase closing argument; and (4) there were constitutional violations in this case. View "State v. Whitaker" on Justia Law

The Supreme Court reversed the judgment of the trial court finding Defendant guilty of kidnapping and rape and a repeat-violent-offender specification and imposing a ten-year sentence on each count, to be served concurrently, holding that the trial court denied Defendant his constitutional right to a fair jury as guaranteed by the Sixth and Fourteenth Amendments to the United States Constitution.At issue was whether Defendant's right to a fair trial was violated when the alleged victim was introduced to the jury as the State's designated representative and was permitted to sit at counsel table with the prosecutor during the proceedings. The court of appeals affirmed. The Supreme Court reversed, holding that the trial court erred in designating the alleged victim as the State's representative and by allowing her to sit at the prosecutor's table and that the error was not harmless, requiring reversal. View "State v. Montgomery" on Justia Law

The Supreme Court determined that a warrantless search conducted in this case did not comport with the Fourth Amendment under the "single-purpose-container exception" to the warrant requirement, holding that when police search a bookbag in a home under circumstances that do not give rise to any exigency they must first obtain a warrant.After he was charged with illegal possession of drugs Defendant filed a motion to suppress, arguing that the warrantless search of the book bag conducted by a law enforcement officer was unlawful. The trial court denied the motion, concluding that the warrantless search was lawful because the book bag was in plain view and the officer had probable cause to suspect it contained contraband. The court of appeals affirmed. The Supreme Court reversed, holding (1) absent exigent circumstances, the search of a closed container requires a warrant; and (2) the single-purpose-container exception to the warrant did not apply in this case because a bookbag is not a single-purpose drug container. View "State v. Burroughs" on Justia Law

The Supreme Court held that the General Assembly-district plan adopted by the Ohio Redistricting Commission on May 5, 2022 was invalid in its entirety and ordered the commission to draft and adopt an entirely new General Assembly-district plan that meets the requirements of the Ohio Constitution, including Article XI, Sections 6(A) and 6(B).On May 5, the Commission readopted the plan at issue, purportedly only for use in the 2022 election. The Supreme Court had earlier held the plan to be unconstitutional. Petitioners filed objections to the adoption of the plan. The Supreme Court sustained the objections, holding that the plan at issue was invalid in its entirety. View "League of Women Voters of Ohio v. Ohio Redistricting Commission" on Justia Law