In re J.V., 134 Ohio St. 3d 1

Juvenile J.V. pleaded to felonious assault, aggravated robbery, and related youthful-offender specs; received a blended sentence with ODYS custody and a stayed adult term.
The stayed adult sentence was later invoked after J.V. was involved in a fight near the end of his ODYS term.
J.V. challenged the invocation on two grounds on discretionary appeal; the court of appeals affirmed the invocation, and this court reviewed de novo.
The court discusses RC 2152.14’s invocation provisions, the standards of proof, and related due process protections under Blakely/Foster.
The 21st birthday of J.V. occurred during proceedings, raising questions about juvenile court jurisdiction over the once-adjudicated delinquent.
The majority affirms in part and reverses in part, with a concurrence and dissents addressing jurisdictional issues and Fischer-related limits.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether RC 2152.14(E) invocation uses improper jury findings	J.V. argues Apprendi precludes judicial fact-finding	State argues no jury required; standard is clear and convincing	No jury-right violation; no increase beyond maximum as to the stayed sentence
Whether the clear-and-convincing standard satisfies due process	J.V. contends process is deficient	State contends standard is appropriate for invocation proceeding	Clear-and-convincing standard is constitutionally permissible for invocation
Whether the juvenile court had jurisdiction to impose/adjust after age 21	J.V. contends court lost jurisdiction at 21	State argues jurisdiction existed for correction of void sentences	Juvenile court lacked jurisdiction to impose/posture 21-era adjustments; disposition void as to jurisdiction
Whether Fischer controls limits on review of void sentences and postrelease control	J.V. seeks broader review beyond resentencing	State relies on Fischer to limit appellate scope	Fischer governs limitations; postrelease-control correction may be pursued; but void adult portion recognized

In re J.V., 8th Dist. Nos. 86849 and 86850, 2006-Ohio-2464 (Ohio (Eighth Dist. 2006)) (sentencing entries and postrelease-control issues in JV case referenced but not fully cited here)
State v. D.H., 120 Ohio St.3d 540 (2009-Ohio-9) (framework for invocation of adult portion of SYO sentence; due process protections)
In re M.P., 124 Ohio St.3d 445 (2010-Ohio-599) (de novo review standard; context for this appeal)
In re C.P., 131 Ohio St.3d 513 (2012-Ohio-1446) (SYO disposition; evidentiary standards and discretionary invocation)
State v. Fischer, 128 Ohio St.3d 92 (2010-Ohio-6238) (void-sentences doctrine; limits on resentencing review)
Apprendi v. Jersey, 530 U.S. 466 (2000) (requires jury for facts increasing penalty beyond statutory maximum)
Blakely v. Washington, 542 U.S. 296 (2004) (applies to judicial findings affecting sentencing)
Foster, 2006-Ohio-856 (Ohio Supreme Court) (removal of mandatory sentencing enhancements and Apprendi concerns)
Agler, 19 Ohio St.2d 70 (1969) (juvenile due process and jury rights historical posture)
Minnesota v. Murphy, 465 U.S. 420 (1984) (parole/probation revocation due process standards)