In re K.S.J., 2011 Ohio 2064

K.S.J. was 17 at disposition and charged with delinquency for an act that would be an aggravated robbery with a firearm specification, a first-degree felony if committed by an adult.
An adjudicatory hearing on August 25, 2010, K.S.J. admitted to one count of aggravated robbery with a firearm specification.
At the September 21, 2010 dispositional hearing, the court ordered K.S.J. committed to DYS for a four-year term (minimum one year with the firearm spec, potentially extending to age 21).
The court did not personally address K.S.J. to permit allocution at the dispositional hearing, though defense counsel participated and K.S.J. testified during the adjudicatory phase.
K.S.J. timely appealed; the court vacated the disposition and remanded for a dispositional hearing with allocution, while upholding most other aspects of the judgment.
The court concluded K.S.J.'s admission did not fail under Juv.R.29(D)(1) due to substantial compliance.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether allocution rights were violated at disposition.	K.S.J. contends no personal allocution was provided.	State contends allocution is not required at disposition, relying on prior decisions; but precedent acknowledged some allocution right.	Yes; allocution rights violated; disposition vacated and remanded for allocution.
Whether K.S.J.’s admission complied with Juv.R.29(D)(1).	K.S.J. argues lack of explicit understanding of the allegations/plea invoked due process concerns.	Court fully explained the charge, penalties, and rights; admission was voluntary and intelligent.	Substantial compliance found; admission valid.

In re C.S., 115 Ohio St.3d 267 (2007-Ohio-4919) (due process; juveniles entitled to careful inquiry in admissions)
In re J.R.P., 175 Ohio App.3d 481 (2008-Ohio-989) (requires voluntary, intelligent admission with understanding of consequences)
In re R.B., Clark App. No. 2005-CA-94, 2006-Ohio-264 (2006-Ohio-264) (allocution rights in delinquency adjudications)