In re M.I.
2017 Ohio 1524
| Ohio Ct. App. | 2017Background
- In 2012, 16-year-old M.I. was adjudicated delinquent in Gallia County for acts that would be gross sexual imposition if adult, and the case was transferred to Hamilton County for disposition.
- The Hamilton County Juvenile Court committed M.I. to the Department of Youth Services.
- The parties stipulated that M.I. would be classified as a Tier I juvenile offender registrant (lowest tier).
- At the end-of-disposition hearing in 2016, M.I. challenged the mandatory Tier I classification as unconstitutional under equal protection.
- The magistrate found no authority to declassify and continued Tier I; the juvenile court adopted the decision.
- M.I. appealed, arguing the classification scheme violated equal protection.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandatory Tier I classification violates equal protection | M.I. argues no rational basis exists for age-based tiering | State asserts classifications are rationally related to public safety and rehabilitation | No equal-protection violation; classifications are rationally related to public safety |
Key Cases Cited
- State v. Cook, 83 Ohio St.3d 404 (Ohio 1998) (statutory presumptions of constitutionality; burden on challenger)
- State v. Thompkins, 75 Ohio St.3d 558 (Ohio 1996) (rational-basis review and burden on challenger)
- State v. Williams, 88 Ohio St.3d 513 (Ohio 2000) (equal-protection analysis in juvenile-offender context)
- In re R.G., 11th Dist. Geauga No. 2016-G-0064, 2016-Ohio-8426 (11th Dist. Geauga 2016) (juvenile-sex-offender classifications uphold rational basis)