Justia Constitutional Law Opinion Summaries

Appellant Robert Watson, who was serving a custodial sentence, filed a writ of mandamus to compel Appellees, various correctional officials and employees, to provide certain public and nonpublic records directly related to Watson. The court of appeals conditionally granted the writ, stating that Watson must pay for the copies. After Appellees failed to provide the copies to Watson, Watson requested statutory damages in connection with his mandamus case. The court of appeals denied the request. The Supreme Court affirmed, holding that the court of appeals did not abuse its discretion in denying Watson's request, as (1) the court did not conclusively determine that Watson had submitted the applicable cost for the copies; (2) the court did not specify that Appellees had breached any duty owed to Watson; and (3) Watson's mandamus claim was based in part on his request for nonpublic records, which claim was not authorized by Ohio Rev. Code 149.43, and therefore, Watson could not be awarded statutory damages for that claim.

Appellant Timothy Smith pleaded guilty to forgery. The trial court sentenced Smith to five years of community control and required him to pay court costs, the fee for his court-appointed attorney, and $4,857 in restitution. Smith appealed, asserting that the trial court erred when it did not inform him that if he failed to pay court costs, the court could require him to perform community service. The court of appeals refused to consider this assignment of error on its merits, holding that the issue was not ripe for review because Smith had not yet failed to pay court costs. Smith filed a motion in the court of appeals to certify a conflict, alleging that the court's holding conflicted with the Fourth District Court of Appeals' holding in State v. Moss. The Supreme Court reversed, holding that, pursuant to precedent, the court's failure to provide Smith the community-service notice required by Ohio Rev. Code 2947.23(A)(1) was ripe for review regardless of whether Smith had failed to pay costs. Remanded.

This was an action for a writ of mandamus to compel Respondent, the Cuyahoga County fiscal officer, to provide to Relators, private companies that store and index electronic images of records and officials representing those companies, copies of electronic images of all documents recorded in the Cuyahoga County Recorder's Office for two months in 2010, to provide those copies based on their actual cost rather than $2 per electronic image of each page, and to amend the office's public-records policy to comply with the law. The Supreme Court (1) granted the writ to compel the fiscal officer to provide the requested electronic copies at actual cost, as the requested electronic images constituted records subject to disclosure under the Public Records Act and Relators were entitled to copies of those records at actual cost rather than at the higher statutory charge for photocopying documents; and (2) denied the writ insofar as it sought to amend public policy, as the policy it sought to amend was no longer effective and the county's existing public-records policy did not violate the requirement to charge the actual cost of the records.

Appellant Jason Carrick was charged with and convicted of disorderly conduct in violation of Ohio Rev. Code 2917.11(A)(2) after the police department received complaints about the loud music coming from Carrick's property during a Halloween party Carrick hosted in a building he owned. The court of appeals held that section 2917.11(A)(2) was not unconstitutionally vague but thereafter found its judgment to be in conflict with the judgment of the Fourth District Court of Appeals in State v. Compher and certified the record to the Supreme Court for review. At issue was whether section 2917.11(A)(2) provides sufficient notice for a person of ordinary intelligence to understand what he or she is required to do under the law. The Supreme Court affirmed the court of appeals, holding (1) the statute does provide sufficient notice and thus is not void for vagueness, and (2) therefore, Carrick's due-process rights were not violated.

Paul Palmer pleaded guilty to sexual battery in 1995 and served an eighteen-month sentence. Based on Palmer's conviction, the Adam Walsh Act of 2007 automatically imposed a sex-offender classification, requiring registration with authorities. Palmer filed a petition challenging the application of the new registration requirements to him. Meanwhile, Palmer was indicted for violating his registration requirements under the Act. The trial court (1) ruled that Ohio's sex-offender regulations did not apply to Palmer and granted his motion to dismiss the indictment, and (2) ordered the removal of Palmer's name from lists of sex offenders. The Tenth District Court of Appeals reversed, holding (1) the trial court erroneously dismissed the indictment in light of the Act's explicit retroactivity, and (2) because the Act did apply to Palmer, the court erred in requiring removal of Palmer's name from lists of sex offenders. The Supreme Court reversed, holding (1) State v. Bodyke did not invalidate the statutory petition process for challenging a reclassification under the Act; and (2) a trial court may dismiss an indictment alleging violations of the Act based on the retroactive application of the Act because, after State v. Williams, duties under the Act may not be imposed retroactively.

This was an original action in which Relators, thirty-six electors living in various districts for the Ohio House of Representatives as reapportioned by the Ohio Apportionment Board on September 30, 2011, sought declaratory and injunctive relief against Respondents, the four republic members of the five-member Ohio Apportionment Board. Relators sought (1) a declaration that the apportionment plan adopted by the Board was invalid because the Board failed to comply with Ohio Const. art. XI, which governs the decennial apportionment of districts in the General Assembly and the Open Meetings Law, Ohio Rev. Code 121.22; and (2) a prohibitory injunction preventing those Board members from calling, holding, supervising, administering, or certifying any elections under their apportionment plan. The Supreme Court (1) dismissed Relators' open-meetings claim for lack of subject-matter jurisdiction; (2) denied Relators' Article XI claims based on laches insofar as they attempted to challenge the use of the apportionment plan for the 2012 election cycle; and (3) held that Relators' remaining Article XI claims were not barred by laches. The Court stated that it would issue a separate order for further briefing and oral argument on those claims.

After Jose Agosto was convicted and sentenced on criminal charges, Agosto unsuccessfully sought resentencing by raising claims for writs of mandamus and procedendo. Agosto again petitioned for writs of mandamus and procendendo to compel Appellees, a judge and the county court of common pleas, to resentence him to a lawful sentence that constitutes a valid final judgment. The court of appeals denied relief, concluding that res judicata barred Agosto from instituting a successive writ action for the same relief. The Supreme Court affirmed, holding that the court of appeals did not err where (1) res judicata barred Agosto's claims, and (2) some of Agosto's claims were not cognizable in an extraordinary-writ action.

Employee alleged that his political-subdivision Employer committed an intentional tort against him and engaged in negligent conduct. Employer filed a motion for summary judgment on the claims, alleging immunity from suit under the Political Subdivision Tort Liability Act. The trial court denied the motion, concluding (1) a genuine issue of material fact existed, and (2) the express exception to immunity contained in the Act did not apply because Employee's claims did not arise out of the employment relationship. The appellate court affirmed and concluded that the express exception to immunity in the Act prevented Employer from raising immunity pursuant to the Act. The Supreme Court affirmed, holding that the exception to the Act removed the protection of immunity for a political-subdivision employer for injuries to its employees that arise out of the employment relationship, and a political subdivision was at risk for liability in intentional-tort suits that satisfied the terms of Ohio Rev. Code 2745.01.

The Eighth District Court of Appeals certified a conflict between its decision in this case and a decision of the Tenth District Court of Appeals on the question of whether Ohio Rev. Code 2315.21(B), as amended by S.B. 80, was unconstitutional, in violation of the Ohio Constitution, because it was a procedural law that conflicted with Ohio R. Civ. P. 42(B). Section 2315.21(B) created a substantive right to bifurcation in tort actions when claims for compensatory and punitive damages had been asserted. The state Court of Appeals held that section 2315.21(B) was unconstitutional because it conflicted with Rule 24(B), in violation of the separation of powers required by the state Constitution, by purporting to "legislate a strictly procedural matter already addressed by the Civil Rules." The Supreme Court reversed the court of appeals, holding that section 2315.21(B) creates, defines, and regulates a substantive, enforceable right to separate stages of trial relating to the presentation of evidence for compensatory and punitive damages in tort actions and therefore takes precedence over Rule 42(B) and does not violate the Ohio Constitution, as it is a substantive law that prevails over a procedural rule.

Appellant, Marquise Jones, petitioned for writs of mandamus and procendendo to compel Appellee, Sandusdy County Court of Common Pleas Judge Barbara Ansted, to issue a new sentencing entry in Jones's criminal case. The court of appeals dismissed the petition. Jones appealed, arguing that the entry issued in his case was not a final, appealable order because it failed to dispose of every firearm specification of which he was found guilty. The Supreme Court affirmed, holding (1) the sentencing entry constituted a final, appealable order because it set forth the fact of Jones's convictions, the sentence, the judge's signature, and the time stamp indicating the entry upon the journal by the clerk; and (2) Jones had an adequate remedy by way of appeal to raise his claim of sentencing error.