State ex rel. Hughes v. Cuyahoga Cty. (Slip Opinion)
2017 Ohio 7780
| Ohio | 2017Background
- In 2000 Hughes was indicted on two aggravated-murder counts (with specifications), one attempted aggravated-murder count, and four weapons counts in Cuyahoga County.
- In 2001 Hughes pleaded guilty to two aggravated-murder counts and some specifications under a plea agreement; remaining counts/specifications were dismissed; he was sentenced to two consecutive 30-year terms plus 3 years for a firearm specification.
- In March 2015 Hughes filed a motion in his criminal case titled a Crim.R. 32(C) motion seeking revision/correction of the judgment entry and de novo resentencing, presenting six issues for review.
- The trial court denied that motion on May 28, 2015; Hughes did not appeal that denial.
- In May 2016 Hughes filed a mandamus petition in the court of appeals raising the identical six issues and asking for a new sentencing hearing on the ground that the sentencing entry was void.
- The court of appeals dismissed the mandamus petition as barred by res judicata; the Supreme Court of Ohio affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Hughes is entitled to a writ of mandamus ordering a new sentencing hearing because the sentencing entry is void | Hughes argued the sentencing entry was defective and void, entitling him to de novo resentencing | Cuyahoga County argued Hughes’s claims had been presented to and denied by the trial court and therefore are barred by res judicata | Court held claims were barred by res judicata; mandamus denied |
| Whether res judicata precludes relitigation of claims raised in the trial-court motion | Hughes implicitly contended the mandamus action was a proper vehicle notwithstanding the prior denial | County argued final judgment on the motion (trial-court denial) bars the same claims in a subsequent action between same parties | Court held res judicata (claim preclusion/issue preclusion) applies and bars the petition |
Key Cases Cited
- Grava v. Parkman Twp., 73 Ohio St.3d 379 (1995) (explaining res judicata encompasses claim and issue preclusion)
- Brooks v. Kelly, 144 Ohio St.3d 322 (2015) (a final judgment on the merits by a competent court bars subsequent actions on the same claim)
