Justia Constitutional Law Opinion Summaries

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

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

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 holding that a conviction for failure to register as a sex offender under Ohio Rev. Code 2950.04 does not violate a defendant's due-process and jury-trial rights guaranteed by the state and federal Constitutions when the duty to register arises from a juvenile court's delinquency adjudication, holding that such a conviction is not unconstitutional.Appellant was adjudicated delinquent as to what would have been two counts of fourth-degree felony gross sexual imposition if committed by an adult. Appellant was classified as a juvenile-offender registrant and tier I sex offender and was ordered to comply with statutory registration, notification-of-address-change, and verification duties for a period of ten years. Appellant was later convicted for violating a duty to register as a sex offender. On appeal, Appellant argued that his conviction was unconstitutional based on State v. Hand, 73 N.E.3d 448 (Ohio 2016). The court of appeals affirmed. The Supreme Court affirmed, holding (1) that Appellant's conviction for a violation of section 2950.04 for that arose from a juvenile adjudication did not violate Appellant's rights to a jury or due process under the Ohio Constitution and United States Constitution. View "State v. Buttery" on Justia Law

The Supreme Court held that 2015 Am.Sub.H.B. No. 70 (H.B. 70) does not usurp the power of city school boards in violation of Ohio Const. art. VI, 3, and the bill received sufficient consideration for purposes of Ohio Const. art. II, 15(C).The purpose of H.B. 70 was to enact new sections within Ohio Rev. Code Chapter 3302 to authorize community schools and school districts to create community learning centers at schools where academic performance was low. After the bill was signed into law, Appellants moved for a declaratory judgment and permanent injunction, arguing that H.B. 70 was unconstitutional, as was the General Assembly's legislative process in enacting it. The trial court denied the motion for preliminary injunction and declaratory judgment, and the court of appeals affirmed. The Supreme Court affirmed, holding that the enactment of H.B. 70 violated neither the three-consideration rule articulated in Article II, Section 15(C) nor the right of voters to decide the number of members and the organization of the district board of education, as guaranteed by Article VI, Section 3. View "Youngstown City School District Board of Education v. State" 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