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Smith v. Burkhart

L-26-00200

Public records mandamus action sua sponte dismissed where it does not comply with procedural requirements of submitting a complaint to the respondent and filing a written affirmation as set forth in R.C. 149.43(C)(2). Mandamus claim to compel compliance with public records law moot where the records have been provided. Statutory damages under R.C. 149.43 are not available to incarcerated relator.

Sulek

Lucas

9/1/2026

2026-Ohio-3413

State v. Buetner

WD-24-067

For purposes of a motion to suppress, trial court’s finding that defendant voluntarily consented to field sobriety tests and breath test must be affirmed where it is supported by competent, credible evidence such as the interaction being calm and orderly, the arresting officer not raising his voice or threatening or showing force, and the defendant performing the tests without any argument, resistance, delay, or questioning as to whether he must do the tests.

Sulek

Wood

9/1/2026

2026-Ohio-3411

A.H. v. N.H.

WD-25-065

Trial court has subject matter jurisdiction to enter domestic violence civil protection order ("DVCPO") against non-resident where it finds the petitioner is a resident, and that finding is supported by competent, credible evidence. Entry of DVCPO is not against the manifest weight of the evidence where the respondent placed himself in a physical posture of “stepping up” to the petitioner with darkened eyes and closed fists that caused the petitioner to be in fear of imminent physical harm.

Sulek

Wood

8/28/2026

2026-Ohio-3375

State v. Duhart

L-25-00138

Per Mayle, J., deference to jury’s credibility determinations required in manifest-weight review. Conviction not against manifest weight of evidence despite lack of physical evidence. Appellant waived objection to jury instruction on flight. Counsel not ineffective for failing to object to instruction. State’s single reference to appellant’s DNA in national database did not warrant mistrial. Remand necessary for nunc pro tunc entry to correct post-release control.

Mayle

Lucas

8/28/2026

2026-Ohio-3372

State ex rel. Spencer v. Logan

L-26-00087

When taking all of relator’s allegations as true, we find that he is not entitled to clear legal relief. Therefore, we grant respondents’ motion and dismiss relator’s complaint for a writ of mandamus in its entirety.

Osowik

Lucas

8/28/2026

2026-Ohio-3376

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