In re D.S.

The State filed a complaint against D.S. in the juvenile court, alleging that D.S., who was seventeen years old, was delinquent for approaching a couple about to enter their home, brandishing a firearm, and robbing them of their possessions. At the time of the juvenile court’s disposition, D.S. had been held for more than nine months in detention. Defendant requested confinement credit, but the juvenile court denied the request. D.S. appealed. The State conceded that the juvenile court erred in not granting D.S. credit for the time he was confined prior to disposition. On appeal, the court of appeals affirmed the juvenile court’s order. The Supreme Court reversed, holding that Ohio Rev. Code 2152.18(B) requires that predisposition confinement be credited to a juvenile. Remanded for further proceedings, including the proper calculation and award of preconfinement credit. View "In re D.S." on Justia Law