In re C.P., 131 Ohio St. 3d 513

C.P., age 15, was charged in Athens County Juvenile Court with two counts of rape and kidnapping with sexual motivation stemming from acts against a 6-year-old relative.
After amenability and SYO proceedings, C.P. was designated a serious youthful offender (SYO) with stayed adult terms and, as part of SYO, automatically classified as a public-registry-qualified juvenile-offender registrant (PRQJOR) under R.C. 2152.86.
R.C. 2152.86 creates a new PRQJOR class with lifetime in-person registration, verification, and public Internet notification requirements.
The statute imposes these duties automatically, with no discretion for juvenile judges, upon adjudication as SYO.
Ohio’s SB 10 reforms to SORNA are discussed, including national guidelines and varying compliance across states, which the court weighs in the proportionality analysis.
The court ultimately holds that automatic, lifetime PRQJOR registration for juveniles violates the Eighth Amendment and Ohio Constitution Article I, Section 9, as well as due process protections.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Is automatic lifetime PRQJOR registration for juveniles cruel and unusual punishment?	CP argues the punishment is excessive and disproportionate.	State argues registration is civil, nonpunitive, and serves public safety.	Yes, unconstitutional as applied to juveniles.
Does automatic imposition without juvenile-judge discretion violate due process/fundamental fairness?	CP contends lack of discretion undermines rehabilitative aims.	State contends no additional due-process requirements are needed.	Yes, violates due process and fundamental fairness.
Should national consensus and independent review influence the Eighth Amendment analysis?	CP emphasizes lack of national consensus supporting publication.	State emphasizes SB 10/SORNA framework and public safety goals.	The court conducts independent review; national consensus weighs but does not override proportionality concerns.
Does Ohio law balance of rehabilitation vs. punishment support upholding R.C. 2152.86?	CP argues it undermines rehabilitative goals and confidentiality.	State argues statute aligns with public safety and legislative policy.	No; the statute is unconstitutional as applied to juveniles.

Graham v. Florida, 560 U.S. 48 (2010) (proportionality for juveniles; life without parole for nonhomicide is unconstitutional in its class)
Roper v. Simmons, 543 U.S. 551 (2005) (juveniles have lesser culpability; capital punishment unconstitutional for under 18)
D.H. v. State, 120 Ohio St.3d 540 (2009) (juvenile dispositional process and fundamental fairness; juvenile judge's role)
State v. Williams, 129 Ohio St.3d 344 (2011) (SB 10/SORNA punitive characterization; retroactivity and public-safety framework)
Weems v. United States, 217 U.S. 349 (1910) (proportionality; punishment should be graduated to offense)
Kennedy v. Louisiana, 554 U.S. 407 (2008) (categorical limits on punishments; nature of offense matters)
United States v. Juvenile Male, 670 F.3d 999 (9th Cir. 2012) (due process and registration under SORNA not always punitive)
In re Agler, 19 Ohio St.2d 70 (1969) (juvenile system focus on rehabilitation)
Graham (cited), 130 S.Ct. 2011 (2010) (see above)