In re L.N., 2017 Ohio 4471

In 2014, then-15-year-old L.N. admitted to gross sexual imposition involving his 4-year-old sister and was adjudicated delinquent; disposition committed him to ODYS but suspended pending treatment at JRCNO.
The juvenile court deferred ruling on sex-offender classification until release from secure custody.
In April 2015, while at JRCNO, L.N. was charged in a separate gross sexual imposition case; the court then terminated the prior dispositional placement at JRCNO and transferred L.N. to ODYS on June 23, 2015, expressly noting he did not leave secure custody.
The court scheduled a classification hearing to occur upon release from secure custody; because L.N.’s ODYS commitment was later extended, the classification hearing ultimately occurred on July 18 and August 4, 2016, and he was classified as a Tier II juvenile offender registrant.
On appeal, L.N. argued the court committed plain error by conducting the classification hearing more than a year after his alleged "release" from JRCNO; he did not supply transcripts of the classification hearing.
The Sixth District affirmed, holding that because the appellant failed to provide necessary transcripts, the record was incomplete and appellate review must presume regularity; thus plain error could not be shown.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court committed plain error by holding a sex-offender classification hearing over a year after the juvenile’s release from a secure facility	The classification hearing was untimely because it occurred more than a year after L.N. was released from JRCNO; statute does not permit deferral until unrelated dispositional orders expire	The court retained jurisdiction; the dispositional order expressly reserved a post-release classification hearing and L.N. remained continuously in secure custody (transferred, not released)	Affirmed: appellant failed to provide transcripts; record incomplete so plain error cannot be shown and the trial court’s ruling is presumed correct

Knapp v. Edwards Laboratories, 61 Ohio St.2d 197 (appellant bears burden to provide transcript for review)
State v. Long, 53 Ohio St.2d 91 (plain-error review limited and applied with caution)
State v. Skaggs, 53 Ohio St.2d 162 (appellant must show error by reference to record)
State v. Payne, 114 Ohio St.3d 502 (plain error requires clear, prejudicial error on the face of the record)
In re D.J.S., 130 Ohio St.3d 257 (addressing juvenile sex-offender classification issues)