In re Hamblin, 2014 Ohio 3289

December 29–30, 2012, a noise/party complaint in Hamilton involving underage drinking at a residence; Hamblin lived there with Dustin Allen, Christopher Reiff, and Christopher Jordan.
A makeshift stage with a stripper pole and scantily-clad teens was observed; alcohol present in garage and living areas.
A 16-year-old female present at the scene was identified and noted to be heavily intoxicated; officers detected alcohol odor and open containers.
Officer Fryman found a 14-year-old female (T.P.) in a bedroom intertwined with an adult male; appellant was located in another bedroom, claiming the residence.
T.P. initially lied about her age but was later confirmed to be 14; she exhibited slurred speech, red/glassy eyes, and strong odor of alcohol.
The trial court convicted Hamblin of contributing to the unruliness of a child under R.C. 2919.24(A)(1).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether adjudication of the minor is required for conviction under A(1).	State: adjudication not required; proof of status as unruly suffices.	Hamblin: must prove the minor was formally adjudicated.	Not required; evidence showed the minor was unruly.
Whether the evidence supports Contributing to the unruliness under A(1).	State: ample evidence Hamblin aided/unlawfully contributed.	Hamblin: insufficient showing she contributed.	Sufficient evidence supported conviction.

State ex rel. Meng v. Todaro, 161 Ohio St. 348 (1954) (adjudication not necessary before prosecution for contributing to delinquency)
State v. Thompson, 97 Ohio App.3d 629 (1994) (proof of unruly status not required under A(1))
State v. Andriola, 70 Ohio App.3d 69 (1990) (A(2) does not require proof of actual unruliness)