In re C.W., 2013 Ohio 2483

In June 2005, C.W., then 14, was adjudicated delinquent for two counts of rape.
In 2008, he was classified as a Tier III juvenile sex offender under SB10; later vacated due to procedural irregularity.
March 2010, a second classification hearing again labeled him a Tier III offender under SB10; judgment reversed for lack of guardian ad litem.
On remand, the juvenile court classified C.W. as Tier I under SB10; this classification was appealed and stayed pending Supreme Court decisions.
On February 16, 2012, C.W. turned 21; he challenges retroactive application of SB10 and whether remand can reclassify under the law in effect at offense.
The court ultimately held that applying SB10 retroactively violates the Ohio Constitution and that jurisdiction to reclassify under the law in effect at offense no longer exists once C.W. reached 21.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Retroactive application of SB10 violates constitutional retroactivity	C.W. argues SB10 cannot apply to offenses before its effective date.	State contends remand can correct the error using prior law.	Retroactive application is unconstitutional; classification void.

In re Bruce S., 134 Ohio St.3d 477 (2012) (cannot apply SB10 to pre-effective-date offenses)
State v. Williams, 129 Ohio St.3d 344 (2011) (retroactivity clause voids SB10 for pre-2008 offenses)
State v. Carr, 2012-Ohio-5425 () (supports voiding retroactive classification)
In re J.P., 2012-Ohio-3343 () (remand/remedial considerations for SB10 issues)
J.V., 130 Ohio St.3d 261 (2011) (juvenile court lacks jurisdiction after turning 21 for remand under certain dispositions)
A.R.R., 194 Ohio App.3d 40 (2011) (overruled by J.V. on remand jurisdiction after 21)
Billiter, 134 Ohio St.3d 103 (2012) (voids retroactive SB10 classifications when unlawful)