In re L.M., 2012 Ohio 1025

In 2010, Antwon's bike was stolen, and Larry (11) was present nearby during the incident involving Marcellous and Antonio (14–15).
Antonio confronted Marcellous about the bike; Marcellous claimed the bike belonged to a friend, and Antonio grabbed it, then rode away with Larry on the handlebars.
Eyewitnesses testified Larry did not participate in the confrontation or theft; he stood apart, possibly laughing, and was not seen touching the bike.
Three complaints were filed against Larry charging robbery, receiving stolen property, and misrepresenting identity, though the witnesses indicated Larry played no role in the theft.
The juvenile court adjudicated Larry delinquent for robbery under R.C. 2911.02(A)(2) and imposed a four-month probation disposition, stayed pending appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of the evidence	Larry engaged in robbery by complicity.	Larry did not participate or assist; no threat or act by him.	Sufficient evidence supported robbery by complicity.
Manifest weight of the evidence	Weight supports delinquency finding.	Weight favors Larry; no participation or threat.	Adjudication is against the weight of the evidence.

In re J.F., 9th Dist. No. 24490, 2009-Ohio-1867 (9th Dist. 2009) (standard of review for sufficiency in juvenile delinquency cases)
State v. Thompkins, 78 Ohio St.3d 380, 678 N.E.2d 541, (1997) (Supreme Court of Ohio 1997) (comprehensive sufficiency framework and evidentiary review)
State v. Otten, 33 Ohio App.3d 339, 515 N.E.2d 909 (9th Dist. 1986) (9th Dist. 1986) (manifest weight and exceptional-case standard)