2019 Ohio 3298
Ohio Ct. App.2019Background
- At age 14 in 2011, R.B. admitted to acts amounting to two counts of gross sexual imposition involving two four‑year‑old relatives; the magistrate and parties agreed this was a Tier I offense.
- The juvenile court committed R.B. to DYS until age 21 but suspended the commitment and placed him on probation with residential treatment; he and his mother signed notices of Tier I registration duties.
- The magistrate’s January 13, 2012 entries erroneously referenced Tier III in the body but expressly noted they were Tier I; no timely objection was made.
- The juvenile court set a completion‑of‑disposition hearing years later; magistrate decisions in July 2017 continued R.B.’s Tier I classification, and the juvenile court adopted those decisions on October 30, 2017.
- R.B. turned 21 on July 20, 2017, at which point his disposition (commitment until age 21) had, by its terms, ended; the juvenile court’s reclassification order was entered after that date.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the juvenile court had jurisdiction to enter an order continuing R.B.'s Tier I classification after he turned 21 and his disposition ended | State argued the court retained jurisdiction to hold the completion‑of‑disposition hearing and continue the Tier I classification | R.B. argued the court lost jurisdiction when his disposition was completed (upon turning 21), so it could not validly continue the Tier I classification | Court held the juvenile court lacked jurisdiction to continue the Tier I classification after R.B. turned 21 and his disposition had ended; the continuing order was vacated |
Key Cases Cited
- In re Antwon C., 912 N.E.2d 182 (Ohio Ct. App. 2009) (juveniles receive initial classification and a mandatory completion‑of‑disposition reclassification hearing)
- State v. Schulze, 59 N.E.3d 673 (Ohio Ct. App. 2016) (failure to follow statutorily required reclassification process renders subsequent order void)
- State v. Amos, 87 N.E.3d 1305 (Ohio Ct. App. 2017) (juvenile court lacks authority to classify after disposition is completed and juvenile is discharged)
- State ex rel. Jean‑Baptiste v. Kirsch, 983 N.E.2d 302 (Ohio 2012) (juvenile court lacks statutory authority to classify after delinquency adjudication is fully satisfied and juvenile is no longer a child)
- In re Cross, 774 N.E.2d 258 (Ohio 2002) (completion of probation ends juvenile court's jurisdiction over delinquency matter)