Justia Constitutional Law Opinion Summaries

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

Appellees were employed as sales representatives by a company that was owned by Appellants. Appellants filed a class action lawsuit seeking a declaration that certain provisions of Ohio Rev. Code 4111.14 were unconstitutional and a declaration that, as employees, they were entitled to minimum wage. Specifically, Appellants argued (1) because Ohio Rev. Code 4111.14(B)(1) contains exemptions from the definition of “employee” that Ohio Constitution, Article II, Section 34a does not contain, the statute is unconstitutional; and (2) section 4111.14(B) does not apply to claims for minimum wage violations brought under the Constitution. The trial court declared that section 411.14(B)(1) is constitutionally valid and that the exemptions within the statute apply to claims brought under Article II, Section 34a. The Court of Appeals reversed, concluding that the General Assembly exceeded its authority when it defined “employee” differently, and more narrowly, than did the Constitution. The Supreme Court reversed, holding that section 4111.14(B)(1) is constitutional because its definition of the term “employee” does not clearly conflict with the definition of the same term set forth in Article II, Section 34a. View "Haight v. Minchak" on Justia Law

Appellant was convicted of aggravated murder with two felony-murder specifications. Appellant was sentenced to death. After Appellant exhausted his postconviction and federal remedies, the Supreme Court ordered the execution to proceed on September 15, 2009. During the scheduled execution, attempts to insert an IV catheter were unsuccessful. Appellant was injected eighteen times during the botched attempt. Appellant pursued multiple avenues challenging any further attempt by the State to execute him. This appeal arose from Appellant’s successive petition for postconviction relief, in which he asserted that any future attempt to execute him would violate the Cruel and Unusual Punishments and Double Jeopardy Clauses of the United States and Ohio Constitutions. The trial court denied Appellant’s petition without an evidentiary hearing. The Court of Appeals affirmed. The Supreme Court affirmed, holding that the State was not constitutionally barred from carrying out Appellant’s execution. View "State v. Broom" on Justia Law

The juvenile court adjudicated Appellant, a juvenile, delinquent on sex offenses. At disposition, the juvenile court did not record a finding regarding Appellant’s age at the time the offenses were committed. Upon Appellant’s release from the Ohio Department of Youth Services, the court scheduled a sex-offender-classification hearing. Appellant opposed his classification as a juvenile-sex-offender registrant, arguing that he was ineligible for classification because he was under the age of fourteen when the offenses were committed and because classification would violate the constitutional prohibition against double jeopardy. After a hearing, the juvenile court found (1) Appellant had committed at least one offense when he was fourteen years of age, and (2) Appellant should be designated a juvenile offender registrant and classified as a Tier II offender. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a determination of a juvenile sex offender’s age at the time of the offense can be made at any time prior to or during the classification hearing; and (2) the imposition of classification upon release from a secure facility and for a time period beyond the juvenile offender’s attainment of age eighteen or twenty-one does not violate the offender’s due process rights or the constitutional prohibition against double jeopardy. View "In re D.S." on Justia Law

In 2012, a principal of Lipson O’Shea Legal Group made a request for records from Cuyahoga County Board of Health (Cuyahoga County BOH) seeking documentation of homes in the County where a minor child was found to have elevated blood lead levels. Cuyahoga County BOH sought a declaratory judgment with respect to its obligations to maintain the confidentiality of the records sought by Lipson O’Shea. The trial court granted summary judgment for Cuyahoga County BOH, concluding that the release of the records was prohibited by Ohio Rev. Code 3701.01, which exempts from disclosure certain health information if the information could be used to reveal the individual’s identity. The court of appeals reversed, declaring that, rather than withholding all records, Cuyahoga County BOH must examine each document, redact any protected health information, and release any remaining unprotected information not otherwise excepted. The Supreme Court affirmed, holding that some of the information in the requested records prepared by the Cuyahoga County BOH is not protected health information, and therefore, it cannot be said that all of the information responsive to the request is protected. View "Cuyahoga County Bd. of Health v. Lipson O'Shea Legal Group" on Justia Law