Justia Civil Rights Opinion Summaries

The Supreme Court affirmed the decision of the court of appeals refusing to consider for the first time on appeal the State's argument that Defendant lacked Fourth Amendment standing to contest the admission of seized evidence, holding that when the State fails to dispute a defendant's standing in the trial court, it is foreclosed on appeal from attacking the trial court's judgment on these grounds.Defendant filed a motion to suppress, arguing that a detention violated his Fourth Amendment rights. The trial court granted the motion to suppress, concluding that the arresting officer lacked a reasonable, articulable suspicion of criminal activity at the time he detained Defendant. The State appealed, arguing that Defendant lacked standing to contest the admission of the evidence seized. The court of appeals affirmed. The Supreme Court affirmed, holding that where the State did not assert in the trial court that Defendant lacked Fourth Amendment standing to challenge his detention, the State was precluded from asserting that argument in its appeal from the judgment granting Defendant's motion to suppress. View "State v. Wintermeyer" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition for a writ of mandamus, holding that the court of appeals correctly held that Appellant failed fully to comply with Ohio Rev. Code 2969.25(C).In his petition, Appellant sought to compel a common pleas judge to hold a new sentencing hearing and to issue a final, appealable order in his criminal case. The court of appeals dismissed the petition for failure to state a claim, concluding that the petition was procedurally defective because the affidavit of indigence did not contain a statement of the balance in Appellant's inmate account and because Appellant an adequate remedy by law by way of direct appeal. The Supreme Court affirmed, holding that Appellant's failure to comply with the requirements of section 2969.25 required dismissal of his complaint. View "State ex rel. Sands v. Culotta" on Justia Law

The Supreme Court affirmed Defendant's convictions of two counts of aggravated murder and sentence of death for one of the murders but vacated the sentence, holding that the trial court erred in ruling that Defendant was not intellectually disabled.On appeal, Defendant argued that the trial court erred in concluding that he was not intellectually disabled. The Supreme Court remanded the case to the trial court to hold a new hearing to determine whether Defendant was intellectually disabled in accordance with the criteria set forth in this opinion, holding (1) the trial court should have discussed evidence presented on the Flynn Effect, although it was in the trial court's discretion whether to include it as a factor in Defendant's IQ scores; (2) the trial court used the wrong standard in finding that Defendant did not have significant limitations in his adaptive skills; (3) the holding in State v. Lott, 779 N.E.2d 1011 (Ohio 2002), that there is a rebuttable presumption that a defendant is not intellectually disabled if his IQ score is above 70 is no longer valid; and (4) for purposes of eligibility for the death penalty, a court determining whether a defendant is intellectually disabled must consider three core elements set forth in this opinion. View "State v. Ford" on Justia Law

The Supreme Court held that where Defendant was previously convicted of child endangering in connection with the death of his child and then, after his release from prison, Defendant told authorities that he had beaten his son to death, the prohibition against double jeopardy did not prevent the state from prosecuting Defendant for murder or aggravated murder.Defendant originally told authorities that he had accidentally caused his son's death while driving an ATV. Defendant was charged with child endangering and involuntary manslaughter. Defendant entered into a plea agreement whereby he pled guilty to child endangering, and the involuntary manslaughter charge was dismissed. After Defendant served his time in prison, he confessed that he had beaten the child to death and fabricated the ATV accident. Defendant was then indicted for aggravated murder and murder. Defendant filed a motion to dismiss the murder charges, asserting that involuntary manslaughter is a lesser included offense of murder and aggravated murder and that the state was thus barred from prosecuting the charges. The trial court denied the motion. The court of appeals reversed. The Supreme Court reversed, holding that double jeopardy principles did not bar Defendant's prosecution. View "State v. Soto" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals affirming the judgment of the trial court overruling Defendant's motion to suppress evidence relating to a traffic stop, holding that the arresting officer had reasonable suspicion to make an investigatory stop.In affirming the trial court, the court of appeals determined that the discrepancy between the color in the vehicle's registration and the actual color of the vehicle was sufficient to raise the officer's suspicion to that vehicle was either stolen or that the license plate had been taken from another vehicle. The Supreme Court affirmed, holding that when a police officer encounters a vehicle that is painted a different color from the color listed in the vehicle registration records and the officer believes that the vehicle or its license plates may be stolen, the officer has a reasonable, articulable suspicion of criminal activity and is authorized to perform an investigative traffic stop. View "State v. Hawkins" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals reversing the trial court's denial of Appellee's motion to withdraw a guilty plea based on his claim of ineffective assistance of counsel, holding that the trial court erred in denying Appellee's motion without considering the two-prong test for ineffective assistance of counsel established in Strickland v. Washington, 466 U.S. 668 (1984) and applied in the immigration context but that the court of appeals' remand order for a full evidentiary hearing was premature.In his motion, Appellee claimed ineffective assistance of counsel because his attorney had failed to advise him of the immigration consequences of his pleas. The trial court denied the motion. The court of appeals reversed and remanded to the trial court to conduct a hearing, concluding that the trial court erred by denying the motion without deciding whether counsel properly advised Appellee. The Supreme Court affirmed and remanded the matter to the trial court for application of the proper standard, holding that the trial court erred in denying Appellee's motion without considering the two-prong test for ineffective assistance of counsel established in Strickland and applied in Padilla v. Kentucky, 559 U.S. 356 (2010). View "State v. Romero" 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 a handgun and other evidence obtained during a Terry stop, holding that the stop did not violate the Fourth Amendment to the United States Constitution.After hearing the sound of gunshots, two police officers drove to the area where the shots seemed to be coming from. With their guns drawn, the officers detained Defendant, the only person in the area. The officers patted Defendant down and retrieved a handgun from his jacket. Defendant was charged with carrying a concealed weapon. Defendant filed a motion to suppress, arguing that the officers lacked reasonable suspicion to detain him. The trial court denied the motion to suppress. The court of appeals reversed, concluding that the officers had reasonable suspicion to perform an investigative stop. The Supreme Court reversed, holding that, based on the totality of the circumstances, the police officers had reasonable suspicion to stop Defendant and did not convert the stop into an arrest by approaching Defendant with their weapons drawn. View "State v. Hairston" on Justia Law

The Supreme Court granted the writ of mandamus sought by Relator seeking to compel the Ohio Department of Rehabilitation and Correction (DRC) to release security-camera video footage related to a use-of-force incident at Marion Correctional Institution, holding that Relator was entitled to the writ and that Relator was further entitled to attorney fees and statutory damages.DRC argued that the video at issue was not a public record because it qualified as an “infrastructure record” and a “security record,” both of which were exceptions to the definition of a “public record” and therefore not subject to release or disclosure under Ohio Rev. Code 149.433. The Supreme Court disagreed and ordered DRC to provide Relator with an unreacted copy of the requested video, holding (1) the requested record was neither an infrastructure record nor a security record; (2) DRC was required to reimburse Relator for the court costs he paid to commence this action; (3) Relator was entitled to attorney fees and statutory damages; and (4) DRC’s motion for a protective order is denied as moot. View "State ex rel. Rogers v. Department of Rehabilitation and Correction" on Justia Law

The Supreme Court denied the writ of mandamus sought by Relator to compel Kent State University to comply with her records request under Ohio Rev. Code 149.43, holding that Relator was not entitled to additional records beyond those that she had already received pursuant to her request.After Kent State responded to Relator’s records request, Relator filed this mandamus complaint. Following the complaint, Kent State provided additional records. The Supreme Court denied relief, holding that Kent State did not fail to uphold its duties under section 149.43. The Court granted Relator an award of statutory damages in the amount of $1,000 and granted Relator’s request for reasonable attorney fees but denied her request for court costs. View "State ex rel. Kesterson v. Kent State University" on Justia Law

The Supreme Court denied the writ of mandamus sought by Relator seeking to compel Kent State University with certain records regarding student-athletes under the Public Records Act, Ohio Rev. Code 149.43, holding that Relator failed to show by clear and convincing evidence that Kent State failed fully to respond to her records request.Kent State provided several hundred pages of records in response to Relator’s records request. Relator later filed her mandamus complaint alleging that Kent State failed fully to respond to her request. The Supreme Court denied relief, holding (1) despite Kent State’s failure fro comply with Relator’s request within a reasonable period of time, Kent State’s eventual production of all the requested records rendered Relator’s mandamus claim moot; and (2) Relator was entitled to $1,000 in statutory damages and reasonable attorney fees but was not entitled to an award of court costs. View "State ex rel. Kesterson v. Kent State University" on Justia Law