Reid v. Cleveland Police Dept. (Slip Opinion), 2017 Ohio 7527

Tobias Reid pled guilty to petty theft under a plea agreement that included return of his seized vehicle.
The trial court accepted the plea and ordered the Cleveland Police Department to return Reid’s vehicle, but the department had already disposed of it.
Reid moved to vacate his sentence based on the department’s failure to return the vehicle; the trial court denied the motion and Reid appealed his criminal conviction.
On appeal, the Eighth District affirmed the conviction and noted that although the vehicle was scrapped in violation of R.C. 2981.11, vacating the plea was not the appropriate remedy; Reid could seek compensation for the vehicle’s value.
Reid then sued the police department and two officers for $1,000,000 in a civil action; defendants moved for summary judgment asserting statutory immunity and other defenses.
The Eighth District reversed the trial court’s grant of summary judgment, holding the law-of-the-case doctrine bound the civil court to the appellate court’s statements in Reid’s criminal appeal, so summary judgment was improper. The police department appealed to the Ohio Supreme Court.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the law-of-the-case doctrine required the civil court to follow the appellate ruling from Reid’s prior criminal appeal	Reid argued the appellate court’s statements in his criminal appeal (that he was entitled to compensation and that the plea remained valid despite the breached term) should bind the civil case under law-of-the-case	The police department argued law-of-the-case applies only within the same case and does not compel a court in a different case to follow rulings from a prior, separate case	The Ohio Supreme Court held the law-of-the-case doctrine applies only to rulings within the same case; it does not bind courts in different cases, even with a party in common. The Eighth District’s judgment was reversed and the trial court’s summary-judgment order reinstated

Nolan v. Nolan, 11 Ohio St.3d 1 (doctrine applies to subsequent proceedings in the same case)
Christianson v. Colt Industries Operating Corp., 486 U.S. 800 (law-of-the-case fosters finality and efficiency)
Hubbard ex rel. Creed v. Sauline, 74 Ohio St.3d 402 (doctrine ensures consistency and avoids endless litigation)
State ex rel. Potain v. Mathews, 59 Ohio St.2d 29 (discusses preservation of superior/inferior court structure)