State ex rel. Williams v. Sutula (Slip Opinion)
147 Ohio St. 3d 472
| Ohio | 2016Background
- In 1979 Willis F. Williams was convicted of aggravated burglary and attempted murder, sentenced to consecutive terms.
- In 2015 Williams moved to vacate his attempted-murder conviction, arguing the trial court lacked jurisdiction because Ohio does not recognize attempted felony murder.
- Judge John D. Sutula denied Williams’s motion; Williams then filed a mandamus petition in the court of appeals seeking an order to vacate the conviction.
- The court of appeals granted Judge Sutula’s summary-judgment motion and denied the mandamus petition; Williams appealed to the Ohio Supreme Court.
- The Supreme Court reviewed whether attempted felony murder existed at the time of Williams’s 1979 conviction and whether mandamus was appropriate given available remedies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Williams’s attempted-murder conviction is void because attempted felony murder is not a crime | Williams: Nolan means attempted felony murder is not a crime, so the 1979 conviction lacked jurisdiction and must be vacated | Sutula: At the time of conviction (1979) felony-murder was not in the statute, so Williams could not have been convicted of attempted felony murder; claim is meritless | Denied — conviction challenge on attempted felony murder theory lacks merit because felony murder was not a statutory offense in 1979 |
| Whether mandamus is an appropriate remedy | Williams: Mandamus required to compel vacation of a void conviction | Sutula: Williams had an adequate remedy at law (appeal of the motion denial), so mandamus is unavailable | Denied — an appeal from the trial-court denial is an adequate remedy, precluding mandamus |
Key Cases Cited
- State ex rel. Waters v. Spaeth, 131 Ohio St.3d 55 (2012) (elements and burden for mandamus relief)
- State v. Nolan, 141 Ohio St.3d 454 (2014) (holding concerning the felony-murder/attempted-felony-murder analysis)
- State ex rel. Priest v. Dankof, 143 Ohio St.3d 82 (2015) (appeal is an adequate remedy to preclude mandamus)
- State ex rel. Pressley v. Indus. Comm., 11 Ohio St.2d 141 (1967) (appeal as adequate remedy doctrine)