Justia Constitutional Law Opinion Summaries

Several school districts filed complaints seeking reimbursement for retroactive reductions in school foundation funding. The State Board of Education of Ohio (the department) moved for judgment on the pleadings, arguing that it was insulated from liability. The trial court held that the General Assembly did not have the constitutional authority to adjust local school funding retrospectively. The Court of Appeals affirmed. The Supreme Court reversed, holding that the General Assembly had constitutional authority to retroactively reduce the amount of state funding allocated to local school districts and to immunize the department against the school districts’ legal claims. Remanded. View "Toledo City Sch. Dist. Bd. of Educ. v. State Bd. of Educ." on Justia Law

Defendant, a juvenile, was bound over to the common pleas court and indicted on four counts of aggravated murder, among related crimes. Defendant moved to suppress statements he made during a custodial interrogation, arguing that he did not knowingly, intelligently, and voluntarily waive his Miranda rights and that his statements were not voluntary. The trial court denied Defendant’s motion to suppress. Defendant subsequently pled no contest to four counts of aggravated murder, two counts of aggravated robbery, and three counts of tampering with evidence, all with firearm specifications. The Court of Appeals affirmed, holding that where, as in this case, the interrogation of the defendant is recorded electronically, the statements made are presumed to have been made voluntarily pursuant to Ohio Rev. Code 2933.81(B). The Supreme Court reversed, holding (1) section 2933.81(B) does not affect the analysis of whether a suspect intelligently, knowingly, and voluntarily waived his Miranda rights, and therefore, the State retains the burden to prove a valid waiver; and (2) as applied to statements a juvenile makes during a custodial interrogation, the section 2933.81(B) presumption that such statements are voluntary is unconstitutional. Remanded. View "State v. Barker" on Justia Law

After a bench trial, Defendant was found guilty of domestic violence, a misdemeanor in the first-degree. During trial, the victim asserted the privilege against self-incrimination at least eight times in response to questions posed to him about Defendant’s assault. Defendant appealed, raising four claims of error. The court of appeals affirmed. The Supreme Court affirmed, holding (1) Defendant was not prejudiced by the trial court’s inquiry into the victim’s claim of privilege nor by the trial court’s instruction to the victim to read his prior statement during his examination; (2) Defendant failed to establish that an impermissible judicial bias deprived him of a fair trial; and (3) assuming the trial court erred in allowing the victim to read his prior statement at trial, the error was harmless beyond a reasonable doubt. View "State v. Arnold" on Justia Law

Defendant pleaded guilty to the rape and murder of his grandmother and the murder of her husband. Defendant was sentenced to death for the aggravated murders. The Supreme Court affirmed the convictions and death sentences, holding (1) the trial court did not improperly deny Defendant’s request for self-representation; (2) the trial court did not violate Defendant’s right against self-incrimination when it denied Defendant’s motion to suppress certain statements he made; (3) Defendant’s challenges to the trial court’s evidentiary rulings were unavailing; (4) Defendant’s counsel provided constitutionally effective assistance; (5) any misconduct on the part of the prosecutor was not prejudicial; (6) there were no prejudicial errors in the sentencing opinion; and (7) the imposition of the death sentences was appropriate and proportional. View "State v. Obermiller" on Justia Law

Defendant entered a no-contest plea to charges of aggravated robbery and aggravated murder with capital specifications. Defendant was sentenced to death for the murder. The Supreme Court affirmed Defendant’s convictions and death sentence, holding (1) Defendant’s constitutional challenges to Ohio’s death penalty laws were unavailing; (2) the trial court erred by denying one of seven pretrial motions Defendant filed, but in so doing, the trial court did not undermine Defendant’s right to a jury trial; (3) the trial court did not err by denying Defendant’s motion to have a copy of the prosecutor’s complete file turned over to the court for review; (4) the trial court correctly denied Defendant’s motions to suppress his confession; (5) the trial court did not err by admitting fingerprint evidence; (6) the prosecutor did not engage in impermissible misconduct; (7) Defendant received effective assistance of counsel; and (8) Defendant’s death sentence was appropriate. View "State v. Belton" on Justia Law

Relator requested records for public golf courses operated by Cleveland Metroparks. Metroparks declined to provide the records, asserting that they were exempt from disclosure because they were trade secrets or protected by the attorney client privilege. Relator then filed this mandamus action. The court of appeals granted in part and denied in part the request for a writ of mandamus, concluding that Metroparks failed to establish that some documents were exempt from disclosure but that the remaining documents were either trade secrets or protected by the attorney client privilege. The Supreme Court affirmed, holding (1) the court of appeals did not err in denying Defendant’s motion to strike certain affidavits; (2) the court of appeals properly denied Relator’s request for a writ of mandamus with regard to the names and e-mail addresses of Metroparks customers; and (3) the court of appeals did not err by not conducting an in camera review of the documents Relator requested. View "Salemi v. Cleveland Metroparks" on Justia Law

This action raised several challenges to recently enacted legislation and administrative rules related to gambling in the state. Plaintiffs filed an amended complaint against several state entities challenging the constitutionality of video lottery terminals and H.B. 1, the act that authorized them, and legislative actions that related to Ohio’s four casinos, particularly H.B. 277 and H.B. 519. Lastly, Plaintiffs claimed that Ohio Const. art. XV, 6, H.B.1, H.B. 277, and H.B. 519 violate equal protection by granting a monopoly to the gaming operators whom the state approved. The trial court granted the state’s motion to dismiss the action for lack of standing and for failure to state claim, concluding that none of the plaintiffs had standing. The court of appeals affirmed. The Supreme Court affirmed in part and reversed in part, holding (1) Plaintiffs failed to establish that they had organizational standing or standing based on their status as individuals experiencing the negative effects of gambling, parents and a teacher of public-school students, and contributors to the commercial-activity tax; and (2) one plaintiff, however, sufficiently alleged standing to survive Defendants’ motion to dismiss his equal protection claim. Remanded. View "State ex rel. Walgate v. Kasich" on Justia Law

Appellant’s father (Decedent) died after receiving surgery at Aultman Hospital. Appellant requested a copy of Decedent’s complete medical record. The Hospital produced the medical record that existed in the medical-records department. Dissatisfied with the Hospital’s response, Appellant filed this action to compel the production of Decedent’s complete medical record. The trial court granted summary judgment in favor of the Hospital, concluding that the Hospital had produced the requested medical record, as defined by Ohio Rev. Code 3701.74(A)(8). The court of appeals affirmed, concluding that the term “medical record” as that term is used in Ohio Rev. Code 3701.74 does not include all patient data but consists only of information maintained by the medical-records department. The Supreme Court reversed, holding (1) data that was generated in the process of the patient’s healthcare treatment and that pertains to the patient’s medical history, diagnosis, prognosis, or medical condition qualifies as a “medical record”; but (2) “medical record” means any patient data “generated and maintained by a health care provider” without limitation as to the physical location or department where it is kept. Remanded. View "Griffith v. Aultman Hosp." on Justia Law

Appellant made a request for public records and information based on events surrounding the arrest for another individual. When the Ohio Department of Public Safety (ODPS) denied portions of the request, Appellant filed this action in mandamus. The court of appeals dismissed the petition for mandamus, concluding that ODPS had properly denied portions of Appellant’s request. The court subsequently denied Appellant’s application for reconsideration and en banc consideration, concluding that the requests were a nullity. The Supreme Court affirmed, holding that an application for reconsideration or for en banc consideration under the appellate rules cannot be made in an original action. View "State ex rel. Ziegler v. Ohio Dep’t of Pub. Safety" on Justia Law

Appellee was arrested for operating a vehicle while under the influence (OVI). Because he had been convicted of OVI five times in the previous twenty years, Appellee was charged with two fourth-degree felonies under Ohio Rev. Code 4511.19(G)(1)(d) and the repeat-OVI specification described in Ohio Rev. Code 2941.1413 for each offense. Appellee moved to dismiss the repeat-OVI specification attached to each count, arguing that section 2941.1413 violates equal protection because it allows the State to seek greater punishment without providing proof beyond that required to trigger section 4511.19(G)(1)(d). The trial court denied the motion to dismiss, and Appellee pled no contest to both counts. The Court of Appeals reversed, holding that section 2941.1413 violates equal protection. The Supreme Court reversed, holding that section 4511.19(G)(1)(d) and section 2941.1413 are part of a logical, graduated system of penalties for recidivist OVI offenses and do not violate equal protection. View "State v. Klembus" on Justia Law