In re J.L.
2021 Ohio 3823
| Ohio Ct. App. | 2021Background
- Two juveniles (J.L. and J.L. Jr.) faced complaints for aggravated burglary and abduction; state filed SYO specifications and withdrew bindover motions.
- On August 5, 2020, each admitted amended charges and agreed to discretionary Serious Youthful Offender (SYO) blended dispositions (juvenile commitment + stayed adult term).
- September 19, 2020 dispositional journal entries imposed juvenile commitments and stayed adult prison terms, but described the children as “adjudicated delinquent/convicted” or having “pled guilty” (including firearm specifications).
- Each appellant moved to strike references to “convicted” and “pled guilty”; the juvenile court denied the motions.
- Appellants appealed the denial; the court of appeals reversed and remanded, ordering the juvenile court to strike any references to convictions or guilty pleas from the September 19, 2020 entries.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether SYO dispositional entries may describe a juvenile as having pleaded guilty or been convicted | Appellants: SYO admissions are juvenile adjudications, not criminal guilty pleas or convictions; labels "guilty plea/conviction" are improper and harmful | State: Criminal rules/statutes referenced in R.C. 2152.13 apply to SYO cases; juvenile court may impose adult sentence "as if" the child were an adult, so terminology is permissible | Court: Reversed — SYO offenders remaining in juvenile court are adjudicated, not convicted; strike references to "guilty pleas" and "convictions" |
Key Cases Cited
- In re Caldwell, 76 Ohio St.3d 156 (1996) (describing juvenile system goals of care, protection, and rehabilitation)
- In re D.H., 120 Ohio St.3d 540 (2009) (SYO framework keeps cases in juvenile court unless transferred)
- State v. Hand, 149 Ohio St.3d 94 (2016) (application of criminal rules to juveniles does not convert jurisdiction)
- In re C.P., 131 Ohio St.3d 513 (2012) (juvenile rules and confidentiality promote rehabilitation)
- State v. D.B., 150 Ohio St.3d 452 (2017) (reverse bindover requires expungement of adult convictions when case returns to juvenile court)