Justia Civil Rights Opinion Summaries

The Supreme Court reversed the judgment of the court of appeals reversing the judgment of the trial court denying Defendant's motion to withdraw his guilty pleas, holding that Defendant did not meet his burden of establishing that he would not have entered a guilty plea but for the erroneous advice of his plea-stage counsel.Defendant pleaded guilty to sexual battery and attempted induction. Defendant later filed a motion to withdraw his guilty pleas on the grounds that his counsel provided improper advise as to the potential immigration consequences of his pleas. The trial court denied the motion. The court of appeals reversed, holding that counsel was deficient for not "definitively" determining the deportation consequences of Defendant's plea. The Supreme Court reversed, holding that Defendant did not meet his burden of demonstrating that but for his counsel's erroneous advice as to the possibility of relief from deportation he would not have pleaded guilty and would have insisted on going to trial. View "State v. Bozso" on Justia Law

The Supreme Court affirmed Defendant's convictions for aggravated murder, attempted murder, felonious assault, and aggravated arson and sentence of death on the aggravated murder count, holding that no reversible error occurred.Specifically, the Supreme Court held (1) the evidence was sufficient to support the aggravated murder conviction; (2) Defendant's aggravated murder conviction was not against the manifest weight of the evidence; (3) the record did not support Defendant's claim that the trial court denied Defendant standby counsel for the suppression hearing, and the court did not err by allowed Defendant to waive counsel for the mitigation hearing; (4) the trial court's comments prior to the mitigation hearing did not render the mitigation hearing fundamentally unfair; and (5) the death penalty in this case was appropriate and proportional. View "State v. Hundley" on Justia Law

The Supreme Court held that a civil-stalking protection order enjoining future online postings about Plaintiffs imposed an unconstitutional prior restraint on protected speech in violation of the First Amendment.Plaintiffs each filed a petition for a civil-stalking protection order (CSPO) against Defendant. The trial court granted the petitions and issued CSPOs that, among other things, prohibited Defendant from posting about Plaintiffs on any social media service, website, or discussion board. The court of appeals affirmed. The Supreme Court reversed the court of appeals' judgment to the extent that it upheld the trial court's CSPOs enjoining future postings about Plaintiffs or postings that express, imply or suggest that Plaintiffs were culpable in the deaths of their husbands, holding that this portion of the CSPOs did not survive strict scrutiny. View "Bey v. Rasawehr" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals denying a writ of mandamus sought by Appellant to compel Cuyahoga County Court of Common Pleas Judge Daniel Gaul to vacate his convictions, holding that the court of appeals was correct in concluding that Appellant's mandamus request failed as a matter of law.Appellant was found guilty of multiple rape and kidnapping counts and was sentenced to an aggregate prison term of fifty years to life. Appellant later filed a mandamus complaint to compel Judge Gaul to vacate his convictions, alleging that the trial court dismissed the first indictment against him on speedy-trial grounds and that he was protected against reindictment under the Double Jeopardy Clause. The Supreme Court affirmed, holding that Appellant's claims were barred by res judicata. View "State ex rel. Thomas v. Gaul" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals ruling that Appellant, a judgment creditor, did not have standing to bring a private cause of action against a city to enforce the city's obligations to its employees, holding that the right to indemnification set forth in Ohio Rev. Code 2744.07(A)(2) may be asserted only by an employee of a political subdivision.Appellant filed a complaint in federal district court asserted civil rights violations against the City of Cleveland and two of its police detectives. The court granted summary judgment for Cleveland but found that the detectives had violated Appellant's constitutional rights. The court entered a judgment against the detectives in the amount of $13,210,000. Appellant later filed this action against the City asserting, inter alia, claims of statutory indemnification under section 2744.07(B). The common pleas court concluded that the statute required the City to indemnify the officers and pay the judgment. The court of appeals reversed. The Supreme Court affirmed, holding that a judgment creditor may not proceed directly against a political subdivision under section 2744.07(B). View "Ayers v. Cleveland" on Justia Law

The Supreme Court reversed Defendant's convictions for aggravated murder and other felonies and the death sentence imposed by the county court of common pleas, holding that Defendant was deprived of his constitutional right to the effective assistance of counsel when defense counsel, during voir dire, failed to question or strike a racially biased juror.On appeal, Defendant presented seventeen propositions of law. In his seventeenth proposition of law, Defendant argued that his trial counsel provided ineffective assistance by failing to question and strike a juror who made racially biased statements on her juror questionnaire and that counsel's deficient performance denied him a fair and impartial jury. The Supreme Court found this issue dispositive and reversed Defendant's convictions and sentence, holding that defense counsel's performance during voir dire was objectively unreasonable and that counsel's deficient performance prejudiced Defendant in violation of his constitutional right to effective assistance of counsel. The Court remanded the case to the trial court for a new trial. View "State v. Bates" on Justia Law

The Supreme Court reversed the decision of the court of appeals reversing the judgment of the trial court denying Defendant's motion to suppress, holding that a court may consider evidence beyond the four corners of a search warrant affidavit in determining whether an officer reasonably and in good faith relied on that warrant.Defendant was indicted for sexual imposition and voyeurism. Defendant filed a motion to suppress seeking to invalidate a search warrant authorizing the search of his home on the basis that the warrant affidavit contained materially false statements. The trial court ultimately denied the motion to suppress. At issue on remand was whether a detective's testimony regarding his unrecorded conversation with the judge at the time of the approval of the warrant was admissible at the suppression hearing. The court of appeals reversed, holding that the testimony was inadmissible and that the good-faith exception did not apply. The Supreme Court reversed, holding (1) in deciding whether the good-faith exception to the exclusionary rule applies to a search conducted under a search warrant, a court can consider sworn but unrecorded oral information that the police gave to the judge; and (2) because application of the exclusionary rule would not serve to deter any bad police conduct, suppression was unwarranted. View "State v. Dibble" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals concluding that reasonable parental discipline is not a component of the physical-harm element on Ohio's domestic violence and assault statues but, rather, is an affirmative defense to a charge under those statutes, holding that reasonable parental discipline is an affirmative defense.Defendant was charged with one third-degree felony count of domestic violence and one first-degree misdemeanor count of assault for allegedly beating the seven-year-old son of his live-in girlfriend for acting out at school. During trial, Defendant argued that his conduct was a reasonable exercise of parental discipline and corporal punishment. The trial court found Defendant guilty of the charges. The court of appeals affirmed, holding that treating reasonable parental discipline as an affirmative defense and placing the burden of proving that defense upon the accused does not violate due process. The Supreme Court affirmed, holding (1) proof of unreasonable parental discipline is not a component of the physical harm element of the offenses; (2) reasonable parental disciplines an affirmative defense; and (3) treating reasonable parental discipline as an affirmative defense does not unconstitutionally place the burden of proof on the defendant. View "State v. Faggs" on Justia Law

In this certified-conflict case, the Supreme Court held that when an indigent defendant makes an ineffective assistance of counsel claim based upon counsel's failure to request a waiver of court costs, a reviewing court must apply the test in State v. Bradley, 538 N.E.2d 373 (Ohio 1989) for determining whether a defendant received ineffective assistance of counsel.Defendant was convicted of assaulting a peace officer. The trial court assessed court costs against Defendant, despite his indigent status. On appeal, the court of appeals determined that Defendant was not prejudiced by trial counsel's failure to request a waiver of costs and that the basis for a finding of ineffective assistance of counsel for failure to request such a waiver no longer exists. The Supreme Court reversed, holding (1) when trial counsel fails to request that the trial court waive court costs on behalf of an indigent defendant, a determination of prejudice for purposes of an ineffective assistance of counsel analysis deeds on whether there is a reasonable probability that the trial court would have granted the request to waive costs had one been made; and (2) the court of appeals incorrectly analyzed the prejudice prong of the ineffective-assistance of counsel analysis set forth in Bradley. View "State v. Davis" on Justia Law

The Supreme Court granted New Wen, Inc.'s request for a writ of mandamus to compel the Ohio Department of Transportation and its director (collectively, ODOT) to commence appropriation proceedings for an alleged taking of its real property, holding that New Wen showed, by clear and convincing evidence, that ODOT must pay compensation for the taking of the property at issue in this case.At issue was ODOT's closure of a certain intersection, which deprived New Wen of access to a state route. The Supreme Court held that an easement agreement expressly preserved the right of access of New Wen's predecessor-in-title right to the state route and that ODOT's closure of the intersection deprived New Wen of its right of access. Therefore, the Court granted a writ of mandamus to compel ODOT to commence appropriation proceedings and pay compensation for the taking of the property at issue in this case. View "State ex rel. New Wen, Inc. v. Marchbanks" on Justia Law