Justia Constitutional Law Opinion Summaries

The Supreme Court affirmed the judgment of the court of appeals concluding that reasonable parental discipline is not a component of the physical-harm element on Ohio's domestic violence and assault statues but, rather, is an affirmative defense to a charge under those statutes, holding that reasonable parental discipline is an affirmative defense.Defendant was charged with one third-degree felony count of domestic violence and one first-degree misdemeanor count of assault for allegedly beating the seven-year-old son of his live-in girlfriend for acting out at school. During trial, Defendant argued that his conduct was a reasonable exercise of parental discipline and corporal punishment. The trial court found Defendant guilty of the charges. The court of appeals affirmed, holding that treating reasonable parental discipline as an affirmative defense and placing the burden of proving that defense upon the accused does not violate due process. The Supreme Court affirmed, holding (1) proof of unreasonable parental discipline is not a component of the physical harm element of the offenses; (2) reasonable parental disciplines an affirmative defense; and (3) treating reasonable parental discipline as an affirmative defense does not unconstitutionally place the burden of proof on the defendant. View "State v. Faggs" on Justia Law

In this certified-conflict case, the Supreme Court held that when an indigent defendant makes an ineffective assistance of counsel claim based upon counsel's failure to request a waiver of court costs, a reviewing court must apply the test in State v. Bradley, 538 N.E.2d 373 (Ohio 1989) for determining whether a defendant received ineffective assistance of counsel.Defendant was convicted of assaulting a peace officer. The trial court assessed court costs against Defendant, despite his indigent status. On appeal, the court of appeals determined that Defendant was not prejudiced by trial counsel's failure to request a waiver of costs and that the basis for a finding of ineffective assistance of counsel for failure to request such a waiver no longer exists. The Supreme Court reversed, holding (1) when trial counsel fails to request that the trial court waive court costs on behalf of an indigent defendant, a determination of prejudice for purposes of an ineffective assistance of counsel analysis deeds on whether there is a reasonable probability that the trial court would have granted the request to waive costs had one been made; and (2) the court of appeals incorrectly analyzed the prejudice prong of the ineffective-assistance of counsel analysis set forth in Bradley. View "State v. Davis" on Justia Law

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 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 reversed the judgment of the court of appeals affirming the trial court's order permanently enjoining enforcement of Ohio Rev. Code 9.75, which prohibits a public authority from requiring that contractors on public-improvement projects employ a specific number or percentage of the public authority's residents, holding that section 9.75 is a general law and prevails over local laws.The appellate court affirmed the trial court's order permanently enjoining enforcement of section 9.75, holding that Ohio Const. art. II, 34 did not authorize the General Assembly to infringe on the City of Cleveland's municipal home-rule authority under Ohio Const. art. XVIII, 3 to impose city-residency preferences in Cleveland's public-improvement contracts. The Supreme Court reversed and remanded the matter to the trial court to dissolve the injunction, holding that the statute provides for the comfort and general welfare of all Ohio construction employees and therefore supersedes conflicting local ordinances. View "Cleveland v. State" on Justia Law

The Supreme Court denied a writ of mandamus sought by six Williams County electors (Relators) to compel the Williams County Board of Elections and its members to place a petition for a proposed county charter on the November 5, 2019 ballot, holding that Relators had an adequate remedy at law.The Board found that Relators' proposal did not comply with Ohio Const. art. X, 3, which governs county-charter proposals, and determined that the proposal was invalid. In this original action, Relators argued that the Board impermissibly examined the substance of the proposed charter when it should have determined only the sufficiency and validity of the petition and signatures. The Supreme Court denied the writ, holding that Relators failed to show that initial review by a court of common pleas, following by an appeal of right to a court of appeals, afforded them an inadequate remedy at law. View "State ex rel. Fleming v. Fox" 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