Justia Constitutional Law Opinion Summaries

Appellant made a public-records request to the City of South Euclid. After the City failed to respond to the request for nearly six months, Appellant filed a claim for a writ of mandamus. The writ claim became moot when all the requested records were produced during the pendency of the mandamus action. Appellant claimed the she was entitled to statutory damages and attorney fees given that (1) the city delayed two months in providing any response to the request, and (2) the original production of documents was incomplete. The court of appeals denied both statutory damages and attorney fees, concluding that Appellant “failed to establish any viable public benefit.” The Supreme Court (1) reversed the court of appeal’s denial of statutory damages, holding that in authorizing an award of such damages, Ohio Rev. Code 149.43(C)(1) does not condition that award on applying the public-benefit test; and (2) affirmed the denial of attorney fees but on other grounds, holding that the plain language of section 149.43(C)(2)(b) prohibited an award of attorney fees in this case. Remanded. View "State ex rel. DiFranco v. City of S. Euclid" on Justia Law

Appellant made a public-records request to the City of South Euclid in care of the clerk of the city council. The clerk stated that he would forward the requested information, but because of an internal breakdown in communication, the City did not fulfill the request for nearly six months. Appellant filed a claim for a writ of mandamus, after which the oversight was discovered. The City subsequently provided the records responsive to Appellant’s request. Appellant filed a motion for partial summary judgment, contending that although the mandamus action was mooted by the production of records, she was entitled to a mandatory award of attorney fees. The court of appeals denied the motion for fees, concluding that Appellant had “failed to establish any viable public benefit.” The Supreme Court affirmed but on different grounds, holding (1) in considering the question of mandatory attorney fees, the court of appeals should have followed Ohio Rev. Code 149.43(C)(2)(b) rather than looking to public benefit; and (2) because the court did not have to render a judgment ordering the City to produce the records within a reasonable time, Appellant was ineligible for mandatory attorney fees under section 149.43(C)(2)(b). View "State ex rel. DiFranco v. City of S. Euclid" on Justia Law

In 2003, Defendant pleaded guilty to aggravation with a firearm specification. The State and Defendant later agreed that Defendant could withdraw his guilty plea and instead plead guilty to aggravated robbery without a firearm specification and to one count of an attempt to have weapons while under a disability. The new agreement decreased Defendant’s sentence by six months. In 2009, Defendant pled guilty to attempted felonious assault. The trial court sentenced Defendant to a term of imprisonment, to run consecutively to the sentence from the 2003 case. Defendant subsequently sought a writ of habeas corpus, arguing that his 2007 plea and resentencing were void and he was therefore entitled to immediate release. The appellate court denied the writ, concluding that Defendant had already unsuccessfully pursued an adequate legal remedy to challenge his 2007 conviction and could not use habeas corpus to try again. The Court of Appeals affirmed, holding that Defendant’s claim was barred by res judicata. View "Smith v. Buchanan" on Justia Law

Appellant pleaded guilty a violation of Ohio’s RICO statute and a predicate offense of trafficking in marijuana. The trial court imposed a six-year sentence for the RICO offense and an eight-year sentence for the trafficking offense, to be served consecutively. On appeal, Appellant asserted that the trial court’s imposition of consecutive prison sentences violated the prohibition against double jeopardy. The court of appeals affirmed Appellant’s separate sentences. Appellant appealed, arguing that the appellate court was required to apply the standard set forth in State v. Johnson in deciding whether the imposition of multiple convictions and sentences for a RICO offense and one or more of its predicate felonies violated the Allied Offenses statute and his rights under the double jeopardy clauses of the state and federal Constitutions. The Supreme Court affirmed, holding that State v. Johnson is not applicable to a RICO violation and that a RICO offense does not merge with its predicate offenses for purposes of sentencing. View "State v. Miranda" on Justia Law

In September 1991, Appellant was convicted in federal court of criminal offenses and sentenced to federal prison. Meanwhile, in January 1991, the Crawford County Sheriff’s Department served a warrant on Appellant for his arrest after his indictment in Crawford County. Appellant was arraigned in Crawford County then returned to federal custody. In April 1992, Appellant was returned to Crawford County, tried in a jury trial, and convicted of criminal offenses. On appeal, Appellant argued that his speedy-trial rights were violated under the Interstate Agreement on Detainers (IAD). The court of appeals affirmed on appeal and dismissed Appellant’s subsequent petition for a writ of habeas corpus. The Supreme Court affirmed the court of appeals’ denial of a writ of habeas corpus, holding (1) because Appellant was not returned to federal custody after April 1992 until his state court trial had been held, no violation of the IAD occurred; and (2) the court of appeal’s determination on appeal that no violation of the IAD occurred was res judicata as to Appellant’s claims in this case. View "State ex rel. Dye v. Bradshaw" on Justia Law

After a car accident involving David Fraley and Timothy Oeding, Oeding’s insurer (“Auto-Owners”) placed an investigative hold on Fraley’s truck for several months. Fraley filed a negligence action against Oeding’s estate, Oeding’s employer (“J&R”), and Auto-Owners, alleging, among other things, that Auto-Owners’ investigatory hold caused Fraley intangible economic loss due to the loss of use of the truck. The trial court dismissed the complaint, holding (1) the court could not exercise personal jurisdiction over Oeding and J&R solely because their insurer did business in Ohio, and (2) Fraley was not entitled to maintain a direct action against Auto-Owners because he had not obtained a judgment against Auto-Owners’ insureds. The court of appeals reversed, concluding that the trial court erred in its determination that it lacked personal jurisdiction over Oeding and J&R because Auto-Owners’ investigatory hold and its communication with Fraley brought Auto-Owners, and by extension J&R and Oeding, within Ohio’s long-arm statute. The Supreme Court reversed, holding that an Ohio court may not impute an insurance company’s conduct to its nonresident insured for purposes of establishing personal jurisdiction over the insured. View "Fraley v. Estate of Oeding" on Justia Law

At issue in this case was Ohio Rev. Code 4921.25, which grants the Public Utilities Commission of Ohio (PUCO) authority to regulate towing companies as “for-hire motor carriers.” The City of Cleveland filed an action seeking a declaration that the statute violated the Home Rule Amendment of the Ohio Constitution because it was a general law that displaced municipal tow truck ordinances. The trial court granted summary judgment to the State, determining that the statute was a general law that does not violate the Constitution by infringing on the City’s home rule authority. The court of appeals reversed, concluding that the statute was not a general law and therefore unconstitutionally attempted to limit municipal home-rule authority. The Supreme Court affirmed in part and reversed in part, holding (1) the second sentence of the statute violates the Home Rule Amendment by prohibiting the “licensing, registering, or regulation” of entities that tow motor vehicles and so will be severed; but (2) the first sentence of the statute is a general law. View "Cleveland v. State" on Justia Law

Defendant was charged with felony domestic violence, which contained an allegation that Defendant had been previously convicted of two offenses of domestic violence. After a jury trial, Defendant was convicted of domestic violence as charged. The appellate court reversed Defendant’s conviction, determining that the state failed to establish the necessary element of Defendant’s prior domestic violence convictions. The Supreme Court reversed the judgment of the appellate court and reinstated the judgment of the trial court, holding that because, during trial, the defense stipulated to the authenticity of Defendant’s two prior first degree misdemeanor domestic violence convictions, the state did properly prove the instant conviction. View "State v. Tate" on Justia Law

After a jury trial, Defendant was convicted of multiple counts of sexually-related crimes arising from incidents involving underage boys, including rape and gross sexual imposition. Defendant appealed, arguing, among other things, that his confrontation rights were violated when he was not allowed to cross-examine Mark Losko with the Bureau of Criminal Identification and Investigation (BCI) because Losko was not called to testify at trial regarding the DNA profile he created for Defendant and the alleged victims. The court of appeals affirmed the judgment of the trial court, concluding that because Losko's report contained only raw data and because Kristen Slaper, a BCI forensic analyst, testified and was cross-examined regarding her own report linking Defendant to the incriminating DNA evidence, Defendant's Sixth Amendment rights had not been violated. The Supreme Court affirmed, holding (1) when a defendant has stipulated to the admissibility and content of a nontestifying analyst's scientific report, the testimony of a witness who relied on that report does not violate the defendant's right to confrontation; and (2) because Defendant stipulated to Losko's report, he waived any later Confrontation Clause challenge to the use of the report by other witnesses. View "State v. Keck" on Justia Law

Defendant was convicted of failure to comply with a police officer and obstruction of official business. The trial court imposed separate sentences for the two offenses. Defendant appealed, arguing that the offenses should have merged at sentencing as allied offenses of similar import under Ohio Rev. Code 2941.25. The appellate court remanded for a determination as to whether the offenses were allied offenses under State v. Johnson, which instructs courts that a defendant's conduct "must be considered" when determining whether multiple offenses merge at sentencing pursuant to section 2941.25. The trial court determined that the offenses were not allied offenses of similar import and imposed separate prison terms for the two offenses. The court of appeals reversed, concluding that Defendant's sentences merged under Johnson because they were based on the same conduct. The Supreme Court reversed, holding (1) when deciding whether to merge multiple offenses at sentencing pursuant to section 2941.25, a court must review the entire record to determine whether the offenses were committed separately or with a separate animus; and (2) the court of appeals erred by relying on Johnson for the proposition that a court may consider a defendant's conduct only as it was described by the state's theory at trial. View "State v. Washington" on Justia Law