Justia Civil Rights Opinion Summaries

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

The Supreme Court affirmed Defendant's convictions for, among other crimes, two counts of aggravated murder with four death-penalty specifications attached to each count and Defendant's sentence of death, holding that there was no reversible error.Specifically, the Supreme Court held (1) Defendant's argument that the Ohio Constitution limits the right to self-representation was not well taken; (2) Defendant failed to show plain error as to his argument that his standby counsel interfered with his trial preparation and strategy; (3) the evidence was sufficient to support the convictions; (4) there was no abuse of discretion in jury selection; (5) the court did not admit inadmissible victim-impact testimony from witnesses during the trial phase or commit other reversible evidentiary error; (6) there was no prosecutorial misconduct or ineffective assistance of counsel; and (7) Defendant's remaining assignments of error were unavailing. View "State v. McAlpin" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus, holding that Appellant did not show that the parole-revocation proceedings violated his constitutional right to due process.Appellant was convicted of aggravated murder and aggravated robbery and was later released on parole. Appellant was subsequently charged with violating the terms of his parole. After a revocation hearing, the parole board approved the hearing officer's recommendation that Appellant be ordered to serve an additional thirty-six months in prison before again becoming eligible for parole. The parole board approved the recommendation. Appellant filed an action for a writ of mandamus alleging that he was denied the effective assistance of counsel and that reversible error occurred during the revocation hearing. The court of appeals denied the writ. The Supreme Court affirmed, holding that Appellant failed to show that the parole revocation proceedings violated his constitutional right to due process. View "State ex rel. Mango v. Ohio Department of Rehabilitation & Correction" on Justia Law

The Supreme Court affirmed the judgment of the Eleventh District Court of Appeals dismissing Appellant's declaratory judgment and habeas claims but transferring his mandamus claim to the Tenth District Court of Appeals, holding that there was no error.Appellant, an inmate, filed an original action asserting that the revocation of his parole violated his rights to due process, free speech, and equal protection. Appellant sought a declaratory judgment of wrongful imprisonment, a writ of habeas corpus ordering his release from prison, and a writ of mandamus ordering the warden and the chair of the parole board to comply with established controlling law. The Eleventh District dismissed all but the mandamus claim then transferred the action to the Tenth District. The Supreme Court affirmed, holding that Appellant's potential remedy lay in mandamus. View "State ex rel. Guthrie v. Fender" on Justia Law

The Supreme Court reversed the decision of the court of appeals affirming the judgment of the district court denying Petitioner's request for injunctive and declaratory relief claiming that the application of Ohio Rev. Code 2969.271 to his conduct violated his rights under the First and Fourteenth Amendments to the United States Constitution, holding that the lower courts erred.Section 2969.271 allows the Ohio Department of Rehabilitation (DRC) and Correction to administratively extend an incarcerated defendant's prison term beyond his minimum prison term or presumptive earned early-release date but not beyond his maximum prison term. Petitioner entered Alford pleas to attempted burglary and other offenses. The trial court imposed a sentence under the "Reagan Tokes Law." On appeal, Petitioner argued that the sections of the statute allowing DRC to extend his prison term beyond the presumptive minimum term was unconstitutional. The court of appeals concluded that Petitioner's constitutional challenge was not ripe for review. The Supreme Court reversed, holding that a criminal defendant's challenge to the constitutionality of section 2969.271 is ripe for review on the defendant's direct appeal of his conviction and prison sentence. View "State v. Maddox" on Justia Law

The Supreme Court reversed the judgment of the court of appeals denying Appellant's application to reopen his appeal, holding that Appellant's application showed that there was a genuine issue of material fact as to whether he was deprived of the effective assistance of appellate counsel.Appellant pleaded guilty to several sex-related offenses. On appeal, the court of appeals reasoned that, due to an incomplete record, it was compelled to presume regularity in the lower-court proceedings and affirmed the trial court's judgment. Represented by new appellate counsel, Appellant timely filed an application to reopen his direct appeal, asserting that his original appellate counsel's performance was deficient. The court of appeals denied the application. The Supreme Court reversed, holding that Appellant's application to reopen his appeal showed a genuine issue of ineffective assistance of appellate counsel warranting a reopening of the appeal. View "State v. Leyh" on Justia Law