Justia Constitutional Law Opinion Summaries

During the COVID-19 pandemic, the Ohio General Assembly passed a temporary law (H.B. 197) stating that for a limited time, Ohio workers would be taxed by the municipality that was their “principal place of work” rather than the municipality where they actually performed their work. Josh Schaad, who primarily worked from his home in Blue Ash during the pandemic, challenged this law after his employer withheld municipal taxes from his wages and forwarded them to Cincinnati, the location of his employer's business. Schaad's principal argument was that the Due Process Clause of the Fourteenth Amendment to the United States Constitution forbids an Ohio municipality from taxing a nonresident for work performed outside of that municipality. The Supreme Court of Ohio rejected Schaad's argument and affirmed the judgment of the First District Court of Appeals, holding that the Due Process Clause did not prohibit the General Assembly from directing that an Ohio citizen pay taxes to the municipality where the employee’s principal place of work was located rather than to the subdivision of the state where the employee actually worked. The court also held that the General Assembly's power to pass emergency legislation did not expand its substantive constitutional powers. View "Schaad v. Alder" on Justia Law

In this case addressing the General Assembly districting plan adopted by the Ohio Redistricting Commission in September 2023 the Supreme Court granted motions to dismiss brought by Petitioners, who filed motions for leave to file objections instanter to the plan and denied motions to vacate and for leave to file objections, holding that dismissal was warranted.The Commission adopted a new redistricting plan in September 2023 by a unanimous vote. Petitioners moved for leave to file objections. Respondents, members of the Commission, moved to dismiss the cases and to vacate the court's orders declaring the districting plan adopted by the General Assembly in September 2021 as unconstitutional. The Supreme Court granted the motions to dismiss, denied the motions to vacate as moot, and denied the motions for leave to file objections to the September 2023 plan, holding that now that the Commission has adopted a plan with bipartisan support, the facts before the Court bore no resemblance to the allegations in Petitioners' complaints. View "League of Women Voters of Ohio v. Ohio Redistricting Comm'n" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's complaint for writs of mandamus and prohibition ordering the trial court to vacate his criminal sentence, holding that Appellant was not entitled to a writ of mandamus or prohibition.Appellant was convicted of escape, retaliation, and other offenses and sentenced to 26.5 years in prison. Appellant later brought the current action seeking writs of prohibition and mandamus ordering the trial court to vacate his sentencing entries and to grant any other relief to which he was "entitled." The court of appeals dismissed the complaint for failure to state a claim upon which relief can be granted. The Supreme Court affirmed, holding that Appellant had an adequate remedy in the ordinary course of the law through direct appeal to raise his claim that the Sixth Amendment requires that a defendant be expressly informed of his right to counsel at each critical stage of the proceeding and that the trial court's failure to do so in his case rendered his sentence void. View "State ex rel. Rarden v. Butler County Common Pleas Court" on Justia Law

In this case concerning how an Ohio prisoner is to enforce his constitutional right to a speedy trial on an untried indictment the Supreme Court held that a prisoner satisfies the "causes to be delivered" requirement of Ohio Rev. Code 2941.401 when he delivers the written notice and the request to the warden where he is imprisoned, even if the warden fails to deliver the notice and the request to the prosecuting attorney or the appropriate court.Appellant, who was indicted on counts of aggravated robbery and robbery, moved to dismiss the indictment on speedy-trial grounds. The trial court granted the motion, concluding that Appellant had strictly complied with section 2941.401 when he provided written notice of his place of imprisonment and a request for a final disposition and that the 180-day speedy trial time was not tolled by the warden's failure to comply with his duty to send out Appellant's written notices and requests to the prosecuting attorney or the appropriate court. The court of appeals reversed, concluding that Appellant had not strictly complied with the requirements of the statute. The Supreme Court reversed, holding that Appellant caused to be delivered his written notice and request for final disposition under the statute when he provided them to the warden. View "State v. Williams" on Justia Law

The Supreme Court reversed the judgment of the court of appeals reversing Defendant's convictions for felony charges stemming from an inventory search of an impounded truck that Defendant was driving when he was pulled over by a law enforcement officer, holding that the search was reasonable and lawful under the Fourth Amendment.Law enforcement performed an inventory search as to the truck at issue and found a handgun in the truck's right door panel. After Defendant unsuccessfully moved to suppress the evidence of the gun the trial court found him guilty. The court of appeals reversed, holding that the search was not reasonable under the Fourth Amendment because the state's evidence was insufficient. The Supreme Court reversed, holding that the inventory search was lawful. View "State v. Toran" on Justia Law

The Supreme Court affirmed the judgment of the court of appeals granting summary judgment in favor of the Hocking County Common Pleas Court and Judge Dale Crawford in Appellant's action for writs of mandamus and prohibition, holding that the court of appeals correctly determined that the doctrine of res judicata barred Appellant's claims.Appellant was found guilty of assaulting a peace officer. The court of appeals affirmed. About seven years later, Appellant filed a complaint for writs of mandamus and prohibition alleging that the trial court deprived her of her constitutional right to counsel and lacked jurisdiction to hold the sentencing hearing. The court of appeals concluded that the doctrine of res judicata barred Appellant's claims. The Supreme Court affirmed, holding that the court of appeals correctly determined that res judicata barred this mandamus and prohibition action. View "State ex rel. Ogle v. Hocking County Common Pleas Court" on Justia Law

The Supreme Court denied this action brought by Jennifer Giroux and Thomas Brinkman (collectively, Giroux) challenging an initiative petition to place a proposed constitutional amendment on the November 7, 2023 ballot, holding that Giroux failed to show that Ohio law required invalidating the petition.At issue was a petition proposing a constitutional amendment entitled "Right to Reproductive Freedom with Protections for Health and Safety." Giroux brought this challenge alleging that the petition did not comply with Ohio Rev. Code 3519.01(A). The Supreme Court denied relief, holding that section 3519.01(A) does not require a petition proposing a constitutional amendment to include the text of the existing statute, and Giroux's challenge failed for this reason. View "Giroux v. Committee Representing Petitioners" on Justia Law

The Supreme Court vacated the judgment of the court of appeals in this case challenging the constitutionality of the Ohio Liquor Control Commission's emergency rule that was adopted as part of the state's initial response to the COVID-19 pandemic, holding that this appeal and the underlying case were moot.The Commission cited Appellant for violating Rule 80, which was adopted through the emergency procedures prescribed under Ohio Rev. Code 119.03(G). Appellant appealed the order and then initiated a separate civil action for declaratory judgment challenging the constitutionality of the rule. Rule 80 then expired. The trial court dismissed the declaratory judgment action because of the pending administrative appeal. The appellate court affirmed. The Supreme Court vacated the court of appeals' judgment, holding that this case was moot. View "Highland Tavern, L.L.C. v. DeWine" on Justia Law

The Supreme Court held that indefinite sentencing under the "Reagan Tokes Law," which became effective in March 2019 and requires that for certain felony offenses a sentencing court impose on the offender an indefinite sentence consisting of a minimum and a maximum prison term, is not unconstitutional.The two appellants in this case - Christopher Hacker and Danan Simmons - were both subject to sentencing under the Reagan Tokes Law. On appeal, Appellants argued that Ohio Rev. Code 2967.271, which allows the Ohio Department of Rehabilitation and Correction to maintain an offender's incarceration beyond the minimum prison term imposed by a trial court, violates the separation of powers doctrine, procedural due process, and the right to a jury trial. The Supreme Court disagreed and affirmed, holding that Appellants failed to rebut the Reagan Tokes Law's presumption of constitutionality in their facial challenge. View "State v. Hacker" on Justia Law

In this case regarding the removal of a prospective juror based solely on his or her gender the Supreme Court held that when a party objecting to a peremptory challenge offers a bare allegation of gender discrimination without offering other relevant circumstances to support an inference of gender discrimination, that party fails to establish a prima facie case of purposeful gender discrimination.After a jury trial, Defendant was found guilty of the crime of sexual imposition. On appeal, Defendant argued that the prosecutor sought to exclude male jurors because they would tend to sympathize with him. The court of appeals reversed, holding that Defendant established a prima facie case of purposeful discrimination when the state exercised its peremptory challenge on a prospective juror and did not provide a gender-neutral explanation for its challenge. The Supreme Court reversed, holding that the trial court erred when it failed to recognize that Batson v. Kentucky, 476 U.S. 79 (1986), applied to Defendant's objections to the state's peremptory challenges, but the error was immaterial because Defendant failed to establish a prima facie case of discrimination. View "State v. Stalder" on Justia Law