Justia Government & Administrative Law Opinion Summaries

Articles Posted in Supreme Court of Ohio
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This case pertains to a public records request made by Marcellus Gilreath to the Ohio Department of Job and Family Services (ODJFS) and its director, Matt Damschroder. Gilreath sought access to specific records related to him, including his case history in the Client Registry Information System Enhanced (CRIS-E), his Ohio Benefits case history, his overpayment records, and records of any investigation into his alleged theft of food stamps.After not receiving a response from ODJFS or Damschroder for several months, Gilreath filed a mandamus action, following which ODJFS provided him with some of the requested records. Gilreath then requested that the court issue a writ of mandamus to compel ODJFS and Damschroder to allow him to inspect the provided documents in their native electronic format, to search for additional records, and to organize and maintain their emails in a manner that they can be made available for inspection. He also sought an award of statutory damages, court costs, and attorney fees.The Supreme Court of Ohio denied Gilreath's request for a writ of mandamus, finding that ODJFS and Damschroder had no obligation to allow him to inspect the records in their native electronic format. The court also found that ODJFS and Damschroder did not possess or control the county emails Gilreath sought, and that his request for these emails was not sufficiently clear. Furthermore, the court determined that Gilreath had not requested ODJFS and Damschroder to organize and maintain their emails in his original complaint.However, the court did grant Gilreath's request for an award of statutory damages, awarding him $1,000 due to the significant delay in ODJFS's response to his public records request. The court denied his requests for court costs and attorney fees. View "State ex rel. Gilreath v. Cuyahoga Job & Family Services" on Justia Law

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This case involves an appeal from the Tenth District Court of Appeals of Ohio. The appellant is the State of Ohio, represented by the Attorney General, and the appellees are FirstEnergy Corporation, Samuel Randazzo, and a consulting company controlled by Randazzo. Randazzo, the former chairman of the Public Utilities Commission of Ohio (PUCO), allegedly received a $4.3 million bribe from FirstEnergy Corporation. The state of Ohio filed a civil action against Randazzo and his consulting company to recover the proceeds of the bribe. The state sought attachment orders to prevent Randazzo from draining his bank and brokerage accounts. The trial court granted the state’s motion ex parte, without notice to Randazzo and his attorneys. After learning about the court's decision, Randazzo requested a hearing and moved to vacate the orders. The court held a hearing with both sides present and declined to discharge the orders of attachment. Randazzo appealed to the Tenth District Court of Appeals, which found the orders of attachment had been improperly granted. The Court of Appeals determined that the state had failed to meet its burden at the ex parte hearing to establish the irreparable injury requirement.Upon appeal by the state, the Supreme Court of Ohio reversed the judgment of the Court of Appeals and reinstated the orders of the trial court. The Supreme Court held that the Court of Appeals erred by basing its decision on the ex parte requirements. The Supreme Court ruled that the court of appeals should have reviewed the trial court's denial of the motion to vacate the attachment rather than the irreparable injury requirement for an ex parte order. The Supreme Court concluded that the proper remedy for a party dissatisfied with an ex parte attachment order is to request a hearing on the order at which both parties may be heard. It also concluded that Randazzo failed to demonstrate any prejudice from the use of improper garnishment forms. View "State ex rel. Yost v. FirstEnergy Corp." on Justia Law

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The Supreme Court of Ohio found that the Cedar Point Police Department (CPPD), which provides security, policing, and law-enforcement services at the Cedar Point amusement park, is required to respond to valid public-records requests related to those duties. The court concluded that the CPPD is the functional equivalent of a public institution for purposes of the Public Records Act. The court ordered the CPPD to produce any records responsive to the public-records requests by relators WTOL Television, L.L.C., WKYC-TV, L.L.C., and WBNS-TV, Inc. Although the court awarded court costs to the relators, it denied their requests for statutory damages and attorney fees. The case arose after the relators, who are media companies broadcasting news in Ohio, requested records related to a guest injury at Cedar Point and alleged sexual assaults at Cedar Point employee housing. The CPPD, Cedar Fair, and Ronald E. Gilson (the director of security at Cedar Point and the chief of police of the CPPD) failed to provide the requested records, leading to the relators filing a mandamus action. View "State ex rel. WTOL Television, L.L.C. v. Cedar Fair, L.P." on Justia Law

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The Supreme Court affirmed the judgment of the court of appeals dismissing Appellant's petition seeking a writ of prohibition to bar Judge David M. Ondrey of the Geauga County Court of Common Pleas from exercising jurisdiction over a hearing to determine the amount of reasonable attorney fees that Appellant owed based on conduct he committed that the judge found frivolous, holding that there was no error.Appellant sued the Geauga County Republican Central Committee seeking an injunction. Judge Ondrey granted the committee's motion to dismiss. The committee then filed a motion seeking fees it incurred in defending against Appellant's "frivolous" lawsuit. Thereafter, Appellant filed an original action seeking a writ of prohibition to prevent the judge from conducting the hearing on the question of attorney fees. In granting Judge Ondrey's motion to dismiss the court of appeals rejected Appellant's contention that Judge Ondrey exceeded his subject matter jurisdiction by failing strictly to comply with the procedures prescribed by Ohio Rev. Code 2323.51. The Supreme Court affirmed, holding that Judge Ondrey did not patently or unambiguously exceed his jurisdiction. View "State ex rel. Ames v. Ondrey" on Justia Law

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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

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The Supreme Court affirmed the judgment of the court of appeals denying Appellant's complaint for a writ of mandamus requiring the Industrial Commission of Ohio to award him a scheduled award of permanent partial disability (PPD) compensation under Ohio Rev. Code 4123.57(B) for the loss of the use of his right hand, holding that the court of appeals correctly denied the writ.Appellant was injured during the course of his employment as a laborer when he fell from a roof onto concrete below. A district hearing officer granted Appellant's request for scheduled-loss compensation, but a staff hearing officer vacated that order on appeal. The court of appeals denied Appellant's ensuing complaint for a writ of mandamus. The Supreme Court affirmed, holding that some evidence supported the commission's decision denying Appellant's request for compensation for the loss of the use of his right hand, and the commission did not abuse its discretion. View "State ex rel. Block v. Industrial Commission of Ohio" on Justia Law

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The Supreme Court granted a writ of mandamus ordering the Ohio Department of Rehabilitation and Correction to produce a copy of a kite that he alleged he had exchanged with the "cashier" of the North Central Correctional Complex (NCCC), where Relator was incarcerated, holding that Relator was entitled to the writ.According to Relator, an NCCC inspector denied Relator's kite request on the ground that she was not responsible for printing kites. After the department denied Relator's grievance Relator brought this mandamus action seeking production of the kite. The Supreme Court granted the writ, holding (1) Relator showed that he had a clear legal right to the requested relief and that the department had a clear legal duty to provide it; and (2) Relator was not entitled to statutory damages. View "State ex rel. Clark v. Ohio Dep't of Rehabilitation & Correction" on Justia Law

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The Supreme Court reversed the judgment of the court of appeals dismissing Petitioner's mandamus action after recognizing his status as a vexatious litigator as declared in an earlier, separate matter, holding that Petitioner did not "continue" his proceeding as a vexatious litigator in this case.Appellant filed a mandamus action against the Franklin County Board of Commissioners and mailed his objections to a magistrate's decision to the court of appeals. The court in a separate matter subsequently declared Appellant to be a vexatious litigator. Upon filing Appellant's objections in this case, the court of appeals recognized Appellant's status as a vexatious litigator and sua sponte dismissed the case. The Supreme Court reversed, holding (1) when Appellant mailed his objections and filed his motion for leave, he did not "continue" the proceeding as a vexatious litigator under Ohio Rev. Code 2323.52; and (2) therefore, the court of appeals' dismissal was incorrect. View "State ex rel. Mobley v. Franklin County Bd. of Commissioners" on Justia Law

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The Supreme Court denied mandamus relief in this action brought under Ohio's Public Records Act, Ohio Rev. Code 149.43, by Kevin Payne against Kelly Rose, an inspector at the Richland Correctional Institution (RCI), holding that Payne did not have a cognizable claim in mandamus.Payne, an inmate at RCI, sent a public-records request to Rose for a copy of, among other things, JPay support ticket number MACI 1220002928. Rose responded that she obtained the requested record and provided a copy of it to Payne. Payne brought this action seeking a writ of mandamus ordering Rose to produce the requested record and statutory damages. The Supreme Court denied mandamus relief, holding (1) because Payne received his requested record before instituting this action he never had a cognizable claim in mandamus; and (2) statutory damages did not accrue. View "State ex rel. Payne v. Rose" on Justia Law

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The Supreme Court affirmed the orders of the Ohio Power Siting Board approving two large solar farms that were proposed to be built in Preble County, holding that the Board's order was neither unlawful nor unreasonable.The General Assembly authorized commercial solar farms in Ohio but made their construction conditional on the Board's approval. The Board approved the solar farms after its staff agreed to stipulations imposing a number of conditions on the construction and operation of the facilities. Certain citizens appealed. The Supreme Court affirmed, holding that there was nothing unlawful about the Board's adherence to its own regulations and that the Board did not act unreasonably in making the determinations required by Ohio Rev. Code 4906.10(A). View "In re Application of Alamo Solar I, LLC" on Justia Law