In Re D.H., 152 Ohio St. 3d 310

D.H., a 17-year-old, was charged with two counts of robbery in separate juvenile complaints and the juvenile court held discretionary bindover hearings.
The juvenile court deemed D.H. not amenable to juvenile rehabilitation and transferred jurisdiction to adult court under R.C. 2152.12.
D.H. pled no contest in adult court, was sentenced to four years, then successfully appealed the first bindover for failure to articulate reasons; juvenile court again found him not amenable and bound him over.
Rather than waiting until the conclusion of the adult prosecution, D.H. immediately appealed the second bindover orders to the court of appeals.
The state moved to dismiss for lack of a final order; the court of appeals granted the motion and this Court reviewed whether bindover orders are immediately appealable.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Are juvenile discretionary bindover orders immediately appealable as "final orders" under R.C. 2505.02(B)(4)?	D.H.: Bindover is a provisional remedy under R.C. 2505.02(B)(4) and irreparable loss of rehabilitative time makes post-judgment review ineffective.	State: Bindover is not a final order under R.C. 2501.02 (Becker) and waiting for final judgment affords an adequate remedy; immediate appeals cause delay.	The Court held bindover orders are provisional remedies but not final under R.C. 2505.02(B)(4) because appeal after final judgment can provide a meaningful, effective remedy; dismissal affirmed.

In re Becker, 39 Ohio St.2d 84 (1974) (bindover not final under jurisdictional statute absent delinquency finding)
In re A.J.S., 120 Ohio St.3d 185 (2008) (denial of mandatory bindover held final under R.C. 2505.02(B)(4))
State v. Muncie, 91 Ohio St.3d 440 (2001) (provisional-remedy analysis and "bell cannot be unrung" precedent)
State v. Anderson, 138 Ohio St.3d 264 (2014) (immediate appeal appropriate where defendant would lose constitutional protection absent interlocutory review)