In re D.M., 2017 Ohio 232

In 2009, 16-year-old D.M. pleaded true to an amended gross sexual imposition charge in Fulton County juvenile court; parties agreed he would be classified as a Tier I juvenile sex-offender registrant and the case transferred to Medina County for disposition.
The Medina County Juvenile Court issued a dispositional order committing D.M. to probation, requiring sex-offender treatment, and classifying him as a mandatory Tier I registrant; D.M. did not appeal that classification or disposition.
D.M. completed treatment, had probation terminated in 2011, and later sought declassification in 2012 under R.C. 2152.85; the juvenile court denied that petition and D.M. did not appeal the denial.
In 2015 D.M. moved to vacate the original 2009 classification as void, arguing the court had cited R.C. 2152.82 (which applies only if there is a prior sexual adjudication) instead of R.C. 2152.83.
The State conceded the citation error but argued the order was voidable (not void) and barred by res judicata; the juvenile court agreed and corrected the statute reference to R.C. 2152.83. D.M. appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court's 2009 sex-offender classification was void for citing the wrong statute (R.C. 2152.82)	D.M.: classification was void because the court lacked authority under the cited statute	State: citation error made order voidable, not void; res judicata bars collateral attack	Court: classification was voidable (court had statutory authority under R.C. 2152.83); res judicata bars relief; judgment affirmed

State v. Fisher, 128 Ohio St.3d 92 (2010) (distinguishes errors that render sentences void from those that are merely voidable and subject to direct appeal)
State v. Payne, 114 Ohio St.3d 502 (2007) (discusses limits on collateral attack where trial court had statutory authority to act)