In re H.V., 138 Ohio St. 3d 408

H.V. is a juvenile who was delinquent for an act that would have been a felony if committed by an adult (attempted domestic violence, fourth degree) in 2010 while on supervised release for prior domestic-violence offenses.
The juvenile court committed H.V. to the ODYS for a minimum six-month term for that act and merged the supervised-release violation with the underlying charge.
In 2011, after being placed on supervised release, H.V. was charged with second-degree felonious assault and a supervised-release violation, and later revoked and committed to the ODYS for a 90-day minimum for the SR violation and a one-year minimum for the felonious assault.
The trial court ordered the 90-day SR-violation term to run consecutively to the one-year felonious-assault term.
H.V. appealed to the Ninth District alleging (a) exceeding the 30-day minimum under R.C. 5139.52(F) and (b) consecutive service under R.C. 2152.17, which the Ninth District rejected; the Ohio Supreme Court affirmed.
The central question is whether a juvenile court may impose a minimum term longer than 30 days for a SR violation and whether such SR-term may be served consecutively to a new offense term.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a juvenile court may commit a delinquent juvenile to ODYS for more than 30 days for a SR violation.	H.V. contends RC 5139.52(F) limits to a 30-day minimum.	State argues statute permits longer minimums; court may exceed 30 days.	Yes; court may impose more than 30 days.
Whether the SR-violation term may run consecutively to the term for the new offense.	H.V. argues RC 2152.17(F) does not authorize consecutive SR-term to a new offense.	State argues RC 2152.19(A)(8) allows any proper disposition, including consecutive terms.	Yes; court may order consecutive terms under applicable statutes.

In re Caldwell, 76 Ohio St.3d 156 (1996) (catchall authority to order consecutive dispositions (pre-2152 era))
In re Agler, 19 Ohio St.2d 70 (1969) (juvenile disposition principles and rehabilitative focus)
In re C.S., 115 Ohio St.3d 267 (2007) (rehabilitative purposes and statutory framework for dispositions)