Justia Civil Rights Opinion Summaries

The Supreme Court affirmed Defendant's convictions for kidnapping, rape, and murder, holding that when a criminal defendant validly exercises his right to self-representation he can no longer raise claim under the Sixth Amendment to the United States Constitution that his trial counsel - standby or otherwise - was ineffective.In his criminal trial, Defendant waived his right to counsel under the Sixth Amendment and chose to represent himself. The trial court accepted Defendant's waiver and appointed standby counsel to be available to assist Defendant. On appeal, Defendant argued that the trial court violated his Sixth Amendment rights by limiting the role of his standby counsel. The court of appeals affirmed, holding that, based on the court's understanding of the typical role of standby counsel, the trial court did not improperly limit the role of standby counsel. The Supreme Court affirmed, holding that because the trial court had the discretion not to appoint standby counsel at all, the court did not abuse its discretion by appointing standby counsel with a limited role. View "State v. Hackett" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals vacating certain sexually-violent-predator specifications that had been applied to Defendant's sentence, holding that, as applied, the specifications violated the Ex Post Facto Clause of the United States Constitution.Defendant was found guilty of numerous counts of rape, kidnapping, and related crimes involving three victims, including sexually-violent-predator specifications. The court of appeals upheld the convictions on all assignments of error except those challenging Defendant's convictions on the sexually-violent-predator specifications that attached to the crimes that Defendant committed before April 29, 2005. The court vacated the convictions on those specifications as violating the Ex Post Facto Clause. The Supreme Court affirmed, holding that the application of the current version of Ohio Rev. Code 2971.01(H)(1) to Defendant for his crimes in 2003 and 2005 violated the Ex Post Facto Clause. View "State v. Townsend" on Justia Law

The Supreme Court affirmed Defendant's two aggravated murder convictions and death sentences, holding that no reversible error occurred in the proceedings below.Specifically, the Supreme Court held (1) defense counsel were not ineffective for failing to request a change of venue or in filing a joint motion for a gag order; (2) defense counsel were not ineffective for withdrawing Defendant's plea of not guilty by reason of insanity in Defendant's absence or in failing to request a continuance to obtain additional neuroimaging; (3) defense counsel were deficient for failing to object to certain evidence, but the deficient performance did not result in prejudice; (4) defense counsel made an inappropriate comment during mitigation-phase closing argument, but the comment did not prejudice Defendant; (5) Defendant's remaining ineffective assistance of counsel claims were without merit; (6) the trial court did not err in replacing one juror with an alternate juror; and (7) Defendant's sentences were not unlawful. View "State v. Grate" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that a child-abuse investigator employed by a county children-services agency need not give the warnings required by Miranda v. Arizona, 384 U.S. 436 (1966), before questioning a child suspected of committing child abuse, holding that the questioning in this case violated neither Miranda nor the suspect's federal due process rights.The trial court in this case granted the suspect's motion to suppress, finding that the suspect's statement to the agency had been obtained in violation of his due process rights. The court of appeals reversed. The Supreme Court affirmed, holding that where the evidence demonstrated that the child-abuse investigator who interviewed the suspect was neither a law enforcement officer nor acting under the direction or control of the police and where the suspect's confession was not causally related to any conduct of the police, the court of appeals correctly concluded that the confession resulting from the questioning was admissible at trial. View "In re M.H." on Justia Law

The Supreme Court reversed the judgment of the court of appeals upholding Defendant's convictions in a second appeal, holding that Defendant's right to a speedy trial was violated after his case was remanded to the trial court for retrial.The trial court convicted Defendant of two counts of aggravated robbery and one count of failure to comply with an order or signal of a police officer. The court of appeals reversed and remanded the matter. On remand, Defendant pleaded no contest to the charges of having a weapon under disability and failing to comply with an order or signal of a police officer. The court of appeals affirmed, concluding that Defendant's constitutional right to a speedy trial was not violated during the trial court's remand proceedings. The Supreme Court reversed and vacated Defendant's convictions, holding that all four factors under Barker v. Wingo, 407 U.S. 514 (1972) weighed in Defendant's favor. View "State v. Long" on Justia Law

In this case involving a subsidy to offset part of the cost of health insurance that Ohio Public Employees Retirement System (OPERS) provides to retirees receiving an OPERS pension the Supreme Court affirmed the decision of the court of appeals reversing the trial court's dismissal of the action for failure to state a claim, holding that the court of appeals correctly determined that Plaintiff stated a claim under Civ.R. 12(B)(6).Plaintiff filed a class action suit against OPERS arguing that reducing the subsidy of any retiree who is reemployed by a public employer that is a member of the OPERS network violates the Equal Protection Clause of the Ohio Constitution. The trial court dismissed the case under Civ.R. 12(B)(6). The appellate court reversed, holding that Plaintiff stated a claim under Ohio's Equal Protection Clause. The Supreme Court affirmed, holding that Plaintiff alleged facts that, if accepted as true, would entitle him to relief. View "Sherman v. Ohio Public Employees Retirement System" on Justia Law

The Supreme Court affirmed Defendant's conviction of two counts of aggravated murder and sentence of death, holding that no prejudicial error occurred in the proceedings below.Specifically, the Supreme Court held (1) the trial court had jurisdiction over the course-of-conduct death-penalty specification; (2) the trial court did not abuse its discretion in admitting evidence relating to the murder; (3) Defendant was not denied his right to an impartial jury due to the seating of certain jurors; (4) the trial court did not deny Defendant his rights to due process and a fair trial by requiring him to wear leg shackles during the trial; (5) the trial court did not err in ruling that an audiovisual-forensics analyst was a lay witness and allowing him to testify; (6) the trial court did not err in admitting Defendant's videotaped phone conversations; (7) the trial court did not err in admitting autopsy photographs into evidence; (8) no plain error occurred from the prosecutor's statements during the mitigation phase of trial; (9) Defendant received effective assistance of counsel; and (10) Defendant's sentence was constitutional. View "State v. Froman" on Justia Law

The Supreme Court affirmed the judgment of the trial court sentencing Defendant to death for the aggravated murders of Casonya C. and Esme K., holding that there was no prejudicial error in the proceedings below.Defendant was found guilty of two aggravated murders and sentenced to death for each aggravated murder. The Supreme Court later vacated the death sentences and remanded the case to the trial court for resentencing. On remand, the trial court again sentenced Defendant to death for the aggravated murders of Casonya and Esme. The Supreme Court affirmed, holding (1) the trial court did not err by denying Defendant's request for individual sequestered voir dire; (2) the trial court did not commit an obvious error in failing to dismiss a prospective juror sua sponte; (3) Defendant did not receive ineffective assistance of counsel during the resentencing hearing; (4) any error with respect to the prosecutor's comments during closing arguments did not prejudicially affect Defendant's substantial rights; and (5) the death sentences in this case were proportionate and appropriate. View "State v. Kirkland" on Justia Law

The Supreme Court vacated this Court's denial of Defendant's motion to supplement and remanded the case to the court of appeals to consider the issue of whether Defendant knowingly, intelligently, and voluntarily waived his right to trial counsel.Defendant filed a motion to supplement the record with the transcript of a hearing, during which Defendant signed a waiver of his right to trial counsel. The transcript had not been included in the record considered by the court of appeals, which overruled Defendant's argument that he did not knowingly, intelligently, and voluntarily waive his right to counsel. The Supreme Court denied the motion to supplement, but, on further consideration, vacated the denial and granted the motion to supplement the record with the transcript of the hearing. Because the court of appeals was not privy to the complete record of the hearing, the Supreme Court remanded the cause to the court of appeals to render an opinion, upon its review of the supplemented record, the issue of whether Defendant knowingly, intelligently, and voluntarily waived his right to counsel. View "State v. Jones" on Justia Law

The Supreme Court answered questions certified by the United States District Court for the Northern District of Ohio, Eastern Division regarding whether a conviction is a condition precedent to civil liability pursuant to Ohio Rev. Code 2307.60.Plaintiff's complaint asserted claims for civil liability pursuant to section 2307.60 for alleged violations of three criminal statutes: Ohio Rev. Code 2921.05 (retaliation), Ohio Rev. Code 2921.03 (intimidation), and Ohio Rev. Code 2921.45 (interfering with civil rights). Defendants filed a motion to dismiss for failure to state a claim because they had not been convicted of the underlying criminal offenses. The federal court denied the motions to dismiss and then certified questions to the Supreme Court. The Supreme Court answered (1) section 2307.60's creation of a civil cause of action for injuries based on a "criminal act" does not require an underlying criminal conviction; and (2) a criminal conviction is not a condition precedent to a civil claim pursuant to section 2921.03. View "Buddenberg v. Weisdack" on Justia Law