In re P.T., 2013 Ohio 3881

In December 2012, shortly after the Sandy Hook shooting, 15-year-old P.T. posted statements on Facebook praising the massacre and saying he "would have done this job myself if I could have," and later posted an explicit threat in response to another minor.
Multiple parents, students, and school officials in Wilmington, Ohio, saw the posts; police were notified and arrested P.T. for inducing panic (R.C. 2917.31(A)(3)) and aggravated menacing (R.C. 2903.21(A)).
The juvenile court held a contested adjudicatory hearing and found P.T. delinquent for menacing (lesser included offense of menacing under R.C. 2903.22) and inducing panic; disposition included probation, electronic monitoring, counseling, community service, and costs.
P.T. appealed, arguing (1) insufficient evidence of menacing because no specific target or purposeful threat existed, (2) inducing panic lacked a predicate offense, and (3) inducing panic lacked proof of reckless disregard and of causing serious public inconvenience or alarm.
The court reviewed whether the Facebook posts—viewable by the community and made in the immediate aftermath of a high-profile school massacre—were made knowingly such that they would probably cause fear and whether the community response met the statutory standard for inducing panic.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to support menacing (R.C. 2903.22(A))	P.T.: No threat to a specific person or property; no intended target; lacked specific intent	State: Menacing requires only that defendant acted knowingly and caused others to believe they would be harmed; threats may be indirect and need not name a target	Court: Affirmed — sufficient evidence that P.T., aware of Sandy Hook context, knowingly made posts that would probably cause others to fear physical harm
Whether inducing panic (R.C. 2917.31(A)(3)) requires a predicate offense	P.T.: Because menacing was not proven, no predicate offense exists for inducing panic	State: Menacing was proven; thus inducing panic’s predicate is satisfied	Court: Affirmed — menacing was sufficiently proven, so inducing panic predicate requirement is met
Whether inducing panic was supported by evidence of reckless disregard and "serious public inconvenience or alarm"	P.T.: No evacuation or school closure; insufficient public alarm or inconvenience; lacked reckless disregard	State: Posts prompted police contacts, administrative meetings, an automated parent alert, increased security at school, and student absences — showing alarm/inconvenience and reckless disregard	Court: Affirmed — the public response and context show reckless disregard and serious public inconvenience or alarm despite no evacuation

State v. Thompkins, 78 Ohio St.3d 380 (1997) (standard for reviewing sufficiency of the evidence)
State v. Jenks, 61 Ohio St.3d 259 (1991) (appellate function in sufficiency review)
State v. Ali, 154 Ohio App.3d 493 (2003) (menacing can encompass present and future fear; indirect threats may support conviction)