On December 21, 2020, the Court dismissed  State of Ohio v. Christian Carlisle,2020-Ohio-6750 holding that the conflict in the case was improvidently certified. The conflict was whether R.C. 2909.15(D)(2)(b), the reduction provision of the Arson Offender Registration Statute, unconstitutionally violates the separation of powers doctrine. The Court also ordered that the opinion of the court of appeals may not be cited as authority except by the parties inter se. The appeals court had held, in a split decision, that R.C. 2909.15(D)(2)(b) does not violate the separation of powers doctrine.

Read the oral argument preview in the case here and the analysis here.