In Re J.T., 39 N.E.3d 1240

On March 17, 2013, Cincinnati police found juvenile J.T. with a large bulge at his waistband; officers removed a loaded Hi-Point 9mm handgun that was determined in court to be inoperable.
J.T. was charged in juvenile court with carrying a concealed deadly weapon; the charge was amended from a fourth-degree felony to a first-degree misdemeanor when the gun was found inoperable.
A magistrate found J.T. delinquent, concluding the inoperable gun was nonetheless "capable of being used as a deadly weapon." The juvenile court adopted that decision.
The First District Court of Appeals affirmed, reasoning the pistol had been designed as a weapon and could be used as a blunt instrument.
The Ohio Supreme Court accepted discretionary review to decide whether an inoperable handgun not used or brandished as a weapon qualifies as a "deadly weapon" under R.C. 2923.11/2923.12.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an inoperable handgun carried concealed is a "deadly weapon" under R.C. 2923.11/2923.12	The state argued design as a weapon and potential to inflict harm (e.g., as a blunt object) makes it a deadly weapon	J.T. argued that operability or evidence of use as a weapon is required; an inoperable gun tucked in a waistband is not a deadly weapon	The Court held an inoperable handgun that is not used or carried as a weapon is not a "deadly weapon" for purposes of the concealed-weapon statute; conviction vacated

State v. Murphy, 49 Ohio St.3d 206 (1990) (pistol must be operable or readily made operable to qualify as a "firearm" for sentencing specification)
State v. Gaines, 46 Ohio St.3d 65 (1989) (discusses operability requirement for firearm-related enhancements)