Justia Ohio Supreme Court Opinion Summaries

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

Hand entered no-contest pleas in Montgomery County to first-degree felonies (aggravated burglary, aggravated robbery, and kidnapping) and two second-degree counts of felonious assault. Each count had a three-year firearm specification attached, to which Hand also entered no-contest pleas. During the plea hearing, the parties agreed to a total six-year prison term with three of the years being mandatory because they are related to the merged firearm specifications, R.C. 2929.14 and 2941.145. The parties disputed whether the three years for the other offenses was also a mandatory term, based on whether Hand’s prior juvenile adjudication for aggravated robbery under R.C. 2911.01(A)(3) should operate as a first-degree felony conviction to enhance his sentence. The court ruled that Hand’s prior juvenile adjudication required imposition of mandatory prison terms under R.C. 2929.13(F). The appeals court affirmed. The Supreme Court of Ohio reversed. Treating a juvenile adjudication as an adult conviction to enhance a sentence for a later crime is inconsistent with Ohio’s system for juveniles, which is predicated on the fact that children are not as culpable for their acts as adults and should be rehabilitated rather than punished. In addition, juveniles are not afforded the right to a jury trial. View "State v. Hand" on Justia Law

A complaint was filed in juvenile court alleging that A.G. was delinquent for engaging in conduct that, if committed by an adult, would have constituted aggravated robbery and kidnapping, with firearms specifications as to each. A.G. admitted to the allegations in the complaint. The juvenile court found the allegations proved beyond a reasonable doubt and ordered that A.G. be committed to the Department of Youth Services for minimum terms of one year for each of the aggravated robbery and kidnapping adjudications. A.G. appealed, arguing that the juvenile court erred in failing to merge his adjudications for aggravated robbery and kidnapping as “allied offenses of similar import” and that his trial counsel was ineffective for failing to raise the allied-offenses issue. The Court of Appeals denied relief, concluding that the aggravated robbery and kidnapping would constituted allied offenses of similar import under Ohio Rev. Code 2941.25 if committed by an adult but that criminal statutes do not apply in juvenile delinquency proceedings. The Supreme Court reversed, holding that juvenile courts must conduct the same double-jeopardy analysis in delinquency proceedings that other courts apply in adult criminal proceedings to protect a child’s right against double jeopardy. View "In re A.G." on Justia Law

Defendant, a juvenile, was bound over to the common pleas court and indicted on four counts of aggravated murder, among related crimes. Defendant moved to suppress statements he made during a custodial interrogation, arguing that he did not knowingly, intelligently, and voluntarily waive his Miranda rights and that his statements were not voluntary. The trial court denied Defendant’s motion to suppress. Defendant subsequently pled no contest to four counts of aggravated murder, two counts of aggravated robbery, and three counts of tampering with evidence, all with firearm specifications. The Court of Appeals affirmed, holding that where, as in this case, the interrogation of the defendant is recorded electronically, the statements made are presumed to have been made voluntarily pursuant to Ohio Rev. Code 2933.81(B). The Supreme Court reversed, holding (1) section 2933.81(B) does not affect the analysis of whether a suspect intelligently, knowingly, and voluntarily waived his Miranda rights, and therefore, the State retains the burden to prove a valid waiver; and (2) as applied to statements a juvenile makes during a custodial interrogation, the section 2933.81(B) presumption that such statements are voluntary is unconstitutional. Remanded. View "State v. Barker" on Justia Law

T.L.M. appealed the judgments in his three cases. The court of appeals granted a limited remand of the three cases for the juvenile court to rule on the recalculation of credit on his sentence. The juvenile court subsequently awarded T.L.M. additional credit for time served. The State filed a notice of appeal of each of T.L.M.’s cases in the juvenile court, which were dismissed for a procedural defect. The State then filed a second set of notices of appeal with accompanying motions for leave to appeal, but the motions were filed after the deadline for such an appeal had passed. T.L.M. moved to dismiss the appeals for lack of jurisdiction. The court of appeals denied the motions and granted the State’s motions for leave to appeal. T.L.M. requested a peremptory writ to hold in abeyance the appellate court proceedings and prohibit the court of appeals from hearing the appeals. The Supreme Court granted the writ, holding that the court of appeals never obtained jurisdiction to decide whether the State could appeal because the State did not file its motions in the court of appeals before the deadline. View "State ex rel. T.L.M. v. Judges of the First Dist. Court of Appeals" on Justia Law

The juvenile court adjudicated Appellant, a juvenile, delinquent on sex offenses. At disposition, the juvenile court did not record a finding regarding Appellant’s age at the time the offenses were committed. Upon Appellant’s release from the Ohio Department of Youth Services, the court scheduled a sex-offender-classification hearing. Appellant opposed his classification as a juvenile-sex-offender registrant, arguing that he was ineligible for classification because he was under the age of fourteen when the offenses were committed and because classification would violate the constitutional prohibition against double jeopardy. After a hearing, the juvenile court found (1) Appellant had committed at least one offense when he was fourteen years of age, and (2) Appellant should be designated a juvenile offender registrant and classified as a Tier II offender. The court of appeals affirmed. The Supreme Court affirmed, holding (1) a determination of a juvenile sex offender’s age at the time of the offense can be made at any time prior to or during the classification hearing; and (2) the imposition of classification upon release from a secure facility and for a time period beyond the juvenile offender’s attainment of age eighteen or twenty-one does not violate the offender’s due process rights or the constitutional prohibition against double jeopardy. View "In re D.S." on Justia Law

Relator was seventeen years old at the time two delinquency complaints were filed against him. Respondent was the judge of the juvenile division of the county court of common pleas. After a bindover hearing was scheduled, Respondent ordered the state to comply with Relator’s discovery request for several police reports, and the state disclosed all requested documents except for one police report. Relator moved to dismiss the case as a sanction for the failure to produce the report. Respondent dismissed the cases with prejudice as a sanction. The court of appeals reversed. The Supreme Court reversed, holding that the state was required to produce the requested documents. The state then filed a request to schedule a bindover hearing. Respondent granted the state’s motion. Relator sought a writ of prohibition to prevent Respondent from proceeding with the hearing, arguing that his cases had been dismissed with prejudice and had been reviewed by the Supreme Court without remand. The Supreme Court denied the writ, holding that Relator had an adequate remedy in the ordinary course of law by way of appeal, and Respondent did not patently and unambiguously lack jurisdiction to proceed. View "State ex rel. R.W. v. Williams" on Justia Law

J.T., a juvenile, was charged with carrying a concealed deadly weapon for carrying a broken pistol in his waistband that was no longer capable of firing a round. J.T. was found delinquent. The Supreme Court vacated the finding of delinquency, holding (1) an inoperable pistol that is not used as a bludgeoning implement is not a “deadly weapon” for purposes of Ohio Rev. Code 2923.12, which prohibits carrying a concealed weapon; and (2) therefore, there was insufficient evidence in this case to support J.T.’s finding of delinquency for carrying a concealed weapon. View "In re J.T." on Justia Law

In 1992, while he was still a minor, Appellant was adjudicated delinquent for committing the equivalent of an operating a motor vehicle while intoxicated (OVI) offense. Appellant was not represented by counsel during the adjudication. In 2011, Appellant was convicted of OVI offenses that became felonies under the enhancing provision of Ohio Rev. Code 4511.19(G)(1)(d). The State added Appellant’s juvenile OVI adjudication to his four prior adult convictions to reach the “five or more” offenses threshold required to enhance his sentence under section 4511.19(G)(1)(d). Appellant moved to suppress the evidence of his juvenile adjudication, arguing that the adjudication violated his constitutional right to counsel. The trial court overruled the motion to suppress. Appellant was subsequently convicted of two counts and used Appellant’s 1992 juvenile adjudication as an OVI enhancement tool. The Supreme Court reversed and remanded for resentencing, holding that an adjudication of delinquency may not be used to enhance the penalty for a later offense under section 4511.19(G)(1)(d) when the adjudication carried the possibility of confinement, the adjudication was uncounseled, and there was no effective waiver of the right to counsel. View "State v. Bode" on Justia Law

In December 2012, a reporter for the Cincinnati Enquirer requested the court docket showing the cases Hamilton County Juvenile Court Judge Tracie Hunter had presided over during December. The juvenile court administrator sent to the Enquirer the requested documents, but the documents were redacted to provide only the initials of the juveniles. The Enquirer filed this action in mandamus seeking a writ ordering Judge Hunter to reveal the names of the juveniles. The First District Court of Appeals ruled in favor of the Enquirer and ordered Judge Hunter to produce unredacted copies of her docket. In January 2014, the Supreme Court disqualified Judge Hunter from acting as a judge. The Court then dismissed this appeal, as a live controversy no longer existed here because Judge Hunter no longer had power to provide access to the requested records. View "State ex rel. Cincinnati Enquirer v. Hunter" on Justia Law