Justia Constitutional Law Opinion Summaries

Articles Posted in Supreme Court of Ohio
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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

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The Supreme Court affirmed the portion of the court of appeals' judgment upholding the General Assembly's enactment of laws that centralize the collection and administration of net-profits taxes but reversed the portion of the judgment upholding the portion of the legislation allowing the state to retain .5 percent of the collected taxes, holding that the retention provision exceeds the General Assembly's authority.Appellants, several cities and villages, all impose a net-profits tax, which is a tax on income earned within their boundaries. After the General Assembly passed laws imposing centralized administration of those taxes Appellants brought this lawsuit arguing that the legislation violates their home-rule authority and exceeds the General Assembly's constitutional power to limit the power of municipalities to levy taxes. The Supreme Court held (1) the laws imposing centralized administration constitute an act of limitation within the General Assembly's explicit constitutional authority; and (2) the law providing for the state's retention of .5 percent of municipal net-profits taxes a fee or a tax for the state's centralized administration is unconstitutional. View "Athens v. McClain" on Justia Law

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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

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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

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The Supreme Court affirmed the judgment of the court of appeals affirming Defendant's conviction for sexually abusing his granddaughter, holding that acquitted-act evidence was admitted for a proper purpose under Evid.R. 404(B).During trial, the trial court allowed the State to introduce "other acts" evidence that Defendant had previously molested his daughter under similar circumstances. Defendant was put on trial for these allegations but was ultimately acquitted. On appeal, Defendant asked the trial court to categorically rule that admitting evidence related to crimes for which a defendant has been acquitted violates the Double Jeopardy Clause of the Ohio Constitution. The Supreme Court rejected the challenge, holding (1) the Double Jeopardy Clause does not impose a per se bar to the use of other-acts evidence for which the defendant was previously acquitted; and (2) because Defendant placed his intent at issue, the trial court properly admitted evidence of the prior sexual-assault allegations. View "State v. Smith" on Justia Law

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The Supreme Court held that Section 858.01 of the Codified Ordinances of the Village of Put-In-Bay does not impose an unconstitutional tax on motor vehicles.The Village filed separate criminal complaints against Defendants, who operated businesses that made motorized golf cars available for rent within the Village, for failing to pay the annual license fee on their golf carts. The trial court dismissed the criminal complaints on the basis that section 858.01 is for a similar purpose as the annual state license tax levied on the operation of motor vehicles under Ohio Rev. Code 4503.02 and the local government tax permitted by Ohio Rev. Code 4504.02 and 4504.06. The court of appeals reversed, concluding that section 858.01 was not preempted by state law and did not violate Ohio Const. art. XII, 5a. The Supreme Court affirmed, holding (1) the tax is a constitutional exercise of the municipality's right to tax; and (2) section 858.01 does not impose an unconstitutional tax. View "Put-in-Bay v. Mathys" on Justia Law

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The Supreme Court denied the writ of prohibition sought by Relator to prevent the Trumbull County Board of Elections from holding a hearing under Ohio Rev. Code 3501.11(J) and (Q), holding that Relator failed to show that the board was about to exercise quasi-judicial power, that the hearing was unauthorized by law, or that she lacked an adequate remedy in the ordinary course of the law.Section 3501.11(J) empowers the board to investigate violations of election law and report its findings to the secretary of state or the prosecuting attorney. Section 3501.11(Q) empowers the board to investigate the residence qualifications of electors. Relator, who won the Republican nomination to the office of Trumbull County Commissioner and was certified to appear on the November 3, 2020 ballot as a candidate, told Relator that it would hold a public hearing to address allegations regarding Relator's residence and eligibility as an elector during the 2019 through 2020 school year and Relator's alleged misstatements regarding the same. Relator filed a writ of prohibition seeking to prevent the board from holding the hearing.The Supreme Court denied the writ, holding that Relator failed to establish any of the elements showing that she was entitled to a writ of prohibition. View "State ex rel. Frenchko v. Trumbull County Board of Elections" on Justia Law

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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

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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

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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