In re M.R., 2017 Ohio 4134

M.R., a 16–17-year-old, sought certification of a conflict to the Ohio Supreme Court regarding the timing for juvenile sex-offender classification under R.C. 2152.83(A)(1).
The issue centers on whether a juvenile court may classify a first-time 16– or 17–year-old as a juvenile offender registrant before the child's release from a secure facility.
R.C. 2152.83(A)(1) requires the court that adjudicates a delinquent child to issue the classification as part of the dispositional order or, if the child is committed to a secure facility, to issue the order “at the time of the child's release from the secure facility.”
M.R. relied on decisions from several other appellate districts where classification occurred at disposition rather than at release, arguing those cases create a conflict.
The State opposed certification, asserting the present case was factually different because the classification here occurred at the child's release from the secure facility.
The Seventh District denied the motion to certify, finding the present case was distinguishable from the cited districts and therefore not a proper conflict for certification.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2152.83(A)(1) allows classification before release from a secure facility	M.R.: plain language permits classification at disposition (before release) and conflicts exist with other districts	State: this case involved classification at release, so it is factually distinguishable from cases cited by M.R.	Denied certification — no conflict because this case turned on classification occurring at release, not at disposition

Whitelock v. Gilbane Bldg. Co., 66 Ohio St.3d 594 (1993) (sets the three-part test for certifying inter-district conflicts to the Ohio Supreme Court)