In re D.C., 2017 Ohio 114

D.C. was born August 24, 1987. The state filed three indictments (2005–2006) charging crimes committed both before and after he turned 18; the trial-court indictments listed his correct birthdate.
The general-division trial court (no juvenile bindover occurred) consolidated the indictments; D.C. pleaded guilty in May 2006 to several aggravated-robbery counts and related gun specifications. Some of the pleaded offenses occurred while he was a juvenile.
The trial court sentenced D.C. to an aggregate 20 years; several specified counts (one in the second indictment, and the sole count in the third indictment) later were determined to have been adjudicated without subject-matter jurisdiction and were vacated as void.
In October 2015 the state filed a juvenile complaint on the offenses that had occurred while D.C. was a minor; D.C. moved to dismiss on double jeopardy, speedy-trial, and due-process grounds.
The juvenile court denied double-jeopardy and speedy-trial claims but dismissed two counts (Counts 3 and 4) on due-process/fundamental-fairness grounds because D.C. had already served more than the full prison term attributable to those counts.
The state appealed; the appellate court affirmed, concluding Holdcroft’s finality principles applied and dismissal on due-process grounds was warranted given that D.C. had already completed the prison sanction tied to the juvenile-counts at issue.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether dismissal of two juvenile counts violated due process	State: Juvenile prosecution is proper despite prior void convictions; dismissal was error	D.C.: Re-prosecution is fundamentally unfair after he already served the full sentence attributable to those counts	Court: Dismissal affirmed — due process/fundamental fairness barred re-prosecution of counts for which D.C. had already served the complete prison sanction

State v. Wilson, 73 Ohio St.3d 40 (Ohio 1995) (general division conviction void when juvenile court had exclusive jurisdiction)
State v. Simpkins, 117 Ohio St.3d 420 (Ohio 2008) (no legitimate expectation of finality in an unlawful/void sentence not yet fully served)
State v. Holdcroft, 137 Ohio St.3d 526 (Ohio 2013) (when the entirety of a prison sanction has been served, sentence for that crime cannot be modified; finality interest paramount)
In re D.S., 146 Ohio St.3d 182 (Ohio 2016) (Due Process Clause applies in juvenile proceedings; process required depends on fundamental fairness)
In re C.S., 115 Ohio St.3d 267 (Ohio 2007) (juvenile proceedings subject to constitutional due process protections)
In re J.V., 134 Ohio St.3d 1 (Ohio 2012) (constitutional issues in juvenile courts are questions of law reviewed de novo)
In re Z.R., 144 Ohio St.3d 380 (Ohio 2015) (juvenile courts are statutory and have limited jurisdiction)