In re R.G., 2016 Ohio 8426

R.G., age 17 at the time of offenses, pled true to two counts of gross sexual imposition (juvenile delinquency adjudications). Charges arose from sexual assaults on two children while she was babysitting.
She was committed to the Department of Youth Services and, before release, faced a juvenile offender registrant classification hearing under R.C. 2152.83.
R.C. 2152.83 provides age-based treatment: children ≤13 not subject to classification; 14–15 subject to discretionary classification; 16–17 subject to mandatory classification (court still sets tier).
R.G. objected, arguing mandatory classification for 16–17 year olds violates equal protection (and initially raised due process/double jeopardy and Eighth/Fourteenth claims, later withdrawing some claims after Ohio Supreme Court decisions).
The juvenile court classified R.G. as a Tier I juvenile sex offender (annual registration for 10 years); she appealed solely on equal protection grounds.
The Eleventh District affirmed, applying rational-basis review and concluding the age distinctions are rationally related to legitimate state interests (public protection and rehabilitative opportunity for younger juveniles).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2152.83's age-based classification scheme violates equal protection	R.G.: Mandatory classification for 16–17 year olds but discretionary for 14–15 (and exclusion of ≤13) treats similarly situated juveniles differently without rational basis	State: Legislative line-drawing is presumptively valid; age distinctions are rationally related to public-safety and rehabilitation goals (older juveniles more accountable/more likely to need tracking)	Court: No equal protection violation — applied rational-basis review; the statute is rationally related to legitimate governmental interests and presumed constitutional

State v. Cook, 83 Ohio St.3d 404 (1998) (statutes presumed constitutional; burden on challenger)
State v. Thompkins, 75 Ohio St.3d 558 (1996) (constitutional challenges burden on party asserting invalidity)
Massachusetts Bd. of Retirement v. Murgia, 427 U.S. 307 (1976) (line-drawing is legislative function; rational-basis review for age classifications)
Vacco v. Quill, 521 U.S. 793 (1997) (challenger must negate every conceivable rational basis)
State v. Williams, 88 Ohio St.3d 513 (2000) (deference to legislative predictive judgments)
Ohio Apt. Assn. v. Levin, 127 Ohio St.3d 76 (2010) (comparison limited to similarly situated persons; classifications valid if rationally related to legitimate interest)
In re D.S., 146 Ohio St.3d 182 (2016) (Ohio Supreme Court upheld R.C. 2152.83 against due process and double jeopardy challenges)