Justia Constitutional Law Opinion Summaries

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

Plaintiffs, former correctional institution employees and a labor union, filed this action against numerous government Defendants, alleging that 2011 Am.Sub.H.B. No. 153, the budget bill for the 2012-2013 biennium, violates the Ohio Constitution. H.B. 153 modified prior law governing contracts for the private operation and management of a state correctional institution in several ways. The court of common pleas granted Defendants’ motion to dismiss, concluding (1) the court lacked jurisdiction to determine whether employees of privately owned or operated prisons were employees, as defined by Ohio Rev. Code 4117.01(C); and (2) the court had jurisdiction over the constitutional challenges to H.B. 153, but Plaintiffs failed to state a claim that H.B. 153 was unconstitutional. The court of appeals reversed in part and ordered the trial court to hold an evidentiary hearing to determine whether H.B. 153 violates the one-subject rule in Ohio Const. art. II, 15(D). The Supreme Court affirmed in part and reversed in part, holding (1) H.B. 153 is constitutional; and (2) the State Employee Relations Board has exclusive jurisdiction to determine public-employee status under section 4117.01(C). View "State ex rel. Ohio Civil Serv. Employees Ass’n v. State" on Justia Law

This appeal involved Defendant’s motion to suppress evidence of a gun that was found in a search of a car legally parked on a public street that Defendant was sitting in just before his arrest on a warrant for domestic violence. After Defendant was arrested, an officer conducted an inventory search of the car, during which he found a handgun. The district court denied Defendant’s motion to suppress, concluding that there was probable cause to arrest Defendant based on the domestic-violence warrant and that, pursuant to that arrest, the inventory search of the car prior to towing was proper. The Supreme Court reversed, holding that the warrantless inventory search of the lawfully parked vehicle in this case was unreasonable under the Fourth Amendment to the United States Constitution and Ohio Const. art. I, 14. View "State v. Leak" on Justia Law

Defendant pled guilty to one count of unlawful sexual conduct with a minor who was over thirteen but less than sixteen years of age. Defendant, who was twenty-one years old when he committed the offense, was designated a Tier II sex offender/child-victim offender and was required to register with the county sheriff and to verify his residence address every 180 days for twenty-five years. Defendant appealed, arguing that the Tier II sex-offender requirements imposed upon him violated the Eighth Amendment’s prohibition against cruel and unusual punishment. The court of appeals affirmed. The Supreme Court affirmed, holding that the registration and address-verification requirements for Tier II offenders under Ohio Rev. Code 2950 do not constitute cruel and unusual punishment. View "State v. Blankenship" on Justia Law

Defendant was found guilty of two counts of aggravated murder and six counts of attempted murder. Defendant was sentenced to death. On appeal, the Supreme Court reversed Defendant’s convictions, vacated the death sentence, and remanded for a new trial. After a new jury was convened, Defendant was convicted on all charges and specifications and again sentenced to death. The Supreme Court affirmed the convictions and sentence of death, holding (1) no error occurred in the selection and removal of jury members; (2) the trial court did not make erroneous evidentiary rulings that denied him a fair trial; (3) the trial court did not err in its instructions to the jury; (4) the evidence was sufficient to support the convictions; (5) no prejudicial error occurred during the penalty phase; (6) the prosecutor did not commit misconduct during either the guilt phase or penalty phase of trial; (7) Defendant’s counsel provided effective assistance during both phases of trial; and (8) Defendant’s death sentence was appropriate and proportional. View "State v. Dean" on Justia Law