State ex rel. Hawkins v. Frederick, 2025-Ohio-4540

Case Information

Court: Supreme Court of Ohio
Date: 2025-10-02
Citation: 2025-Ohio-4540
Read the Opinion

Summary

Summary: The Supreme Court of Ohio affirmed the dismissal of a habeas corpus petition filed by an inmate whose death sentence was commuted to life without parole, holding that the governor’s clemency did not create a void sentence and that the inmate had not shown his sentence had expired or that the trial court lacked jurisdiction.

Key Holdings

• A commuted sentence by the governor does not create a new judgment subject to judicial review
• The Ex Post Facto Clause does not apply to a commuted sentence imposed under a constitutional statute
• An inmate is not entitled to habeas relief if their maximum sentence has not expired
• A trial court’s jurisdiction is not undermined by a subsequent executive commutation
• A habeas corpus petition must establish that the sentencing court patently lacked jurisdiction or that the sentence is void to succeed

More Information

In 1990, the Appellant was convicted of four counts of aggravated murder and sentenced to death, along with additional sentences for aggravated robbery and firearm specifications. His convictions and sentences were affirmed on direct appeal. In 2011, the governor of Ohio commuted the death sentences to life imprisonment without the possibility of parole. Subsequently, in 2023, the trial court granted him jail-time credit, which he later argued invalidated the prior sentences.

In 2024, the Appellant filed a habeas corpus petition in the Third District Court of Appeals, asserting that his commuted sentence was void because such a sentence was not statutorily available at the time of his conviction and that the trial court had failed to reimpose any sentence after granting jail-time credit. The court granted the warden’s motion to dismiss, finding that the Appellant had not demonstrated entitlement to habeas relief because he was serving a valid sentence imposed by a court with jurisdiction.

On appeal, the Supreme Court of Ohio upheld the dismissal. It held that the governor’s clemency powers are constitutionally granted and allow for substitution of a lesser punishment without creating a new judicial sentence. The court further concluded that the commuted sentence was not void and that the Ex Post Facto Clause did not prohibit the commutation, as it resulted in a lesser punishment than death. Moreover, the Appellant failed to demonstrate that his maximum sentence had expired or that any jurisdictional defect existed in the original sentencing court.

The Court also rejected the Appellant’s request for judicial notice of an Oregon decision, finding it irrelevant and inapplicable to Ohio law. Ultimately, the decision reinforces the limited scope of habeas relief and affirms the executive clemency power as beyond judicial scrutiny when validly exercised.