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Friday, November 15, 2024

Ohio Supreme Court rules on requirements for jury verdict forms

State Supreme Court
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Justice Patrick F. Fischer | Ohio Supreme Court Website

The Supreme Court of Ohio has ruled that a jury verdict form is valid if it includes a reference to the Revised Code section citing the penalty for a crime. The decision was made in a 4-3 ruling, affirming Mario Mays' felony conviction for violating a protection order in Lucas County.

Mays had argued that his conviction should be overturned because the jury verdict form did not explicitly state he was guilty of a fifth-degree felony or specify why his offense warranted such classification. However, Justice Patrick F. Fischer, writing for the majority, stated that referencing the relevant Revised Code section on the verdict form met legal requirements for imposing a higher penalty.

Chief Justice Sharon L. Kennedy and Justices R. Patrick DeWine and Joseph T. Deters supported Fischer's opinion. In contrast, Justice Jennifer Brunner dissented, arguing that state law requires specific information on the verdict form to elevate an offense and this information was absent from Mays' form. Justices Michael P. Donnelly and Melody Stewart joined her dissent.

Mays' ex-wife had previously secured a protection order against him, which he violated in 2017 and again in 2020. He contested his 2020 charge in Lucas County Common Pleas Court but was found guilty by a jury whose verdict referenced R.C. 2919.27 (A)(1) and (B)(3). This statute allows for misdemeanor offenses to be elevated to felonies if certain conditions are met, such as prior convictions.

Mays appealed to the Sixth District Court of Appeals but lost in a split decision favoring his felony conviction despite conflicting opinions from other courts about what constitutes sufficient detail on verdict forms.

Justice Fischer highlighted previous cases where insufficient details led to lower sentencing unless additional elements were specified or code sections cited on forms —a distinction seen as satisfied in Mays’ case due largely because his form indicated violations under both sections A(1) & B(3).

In dissenting views expressed by Brunner’s camp: she argued legislative amendments would need implementation before any references could suffice without more detailed findings; concluding with calls towards sticking closer aligned principles over making presumptive policy judgments based solely upon given circumstances presented herein today’s proceedings

This ruling resolves discrepancies between different district court interpretations regarding what needs inclusion when elevating criminal charges via statutory citation alone versus requiring further elaboration concerning contributing factors leading up escalation from basic misdemeanors into full-fledged felonies instead

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