In re R.N.
2018 Ohio 5006
Ohio Ct. App.2018Background
- In August 2016, 17‑year‑old R.N. allegedly participated in a home invasion in Toledo in which the victim was shot five times; police later arrested accomplice X.A., who implicated R.N. as the shooter.
- State filed juvenile complaints for attempted murder and aggravated robbery (with firearm specifications) and moved for mandatory transfer to adult court under Ohio law for category one/two offenses.
- After the Ohio Supreme Court’s Aalim I decision briefly called mandatory transfer into question, the juvenile court ordered an amenability investigation and held a probable‑cause hearing in April 2017.
- At the probable‑cause hearing the victim identified R.N. as the shooter; police testimony and a photo array identification supported probable cause, and the juvenile court found probable cause to bind over.
- The Ohio Supreme Court later reversed Aalim I (Aalim II), restoring mandatory transfer; the juvenile court then transferred R.N.’s case to the common pleas general division. R.N. pled no contest to attempted murder, a firearm specification, and aggravated robbery and was sentenced to 13 years.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (R.N.) | Held |
|---|---|---|---|
| Whether probable cause existed to bind over R.N. for attempted murder and aggravated robbery | Probable cause supported by victim’s identification, X.A.’s confession implicating R.N., and photo‑array ID | Victim’s statements were inconsistent; initial hospital statements pointed to another shooter and there was no physical evidence tying R.N. to the crime | Probable cause existed: victim’s unequivocal ID and corroborating police evidence were sufficient for bindover |
| Whether transfer to adult court under R.C. 2152.12 was proper | Mandatory transfer proper if probable cause exists for category one/two offenses and firearm spec | Transfer improper absent reliable probable‑cause finding | Transfer upheld because court found probable cause; Aalim II reinstated mandatory transfer authority |
Key Cases Cited
- State v. Aalim, 150 Ohio St.3d 463 (Ohio 2016) (addressed juvenile mandatory transfer and due process; later reconsidered)
- State v. Aalim, 150 Ohio St.3d 489 (Ohio 2017) (overturned earlier decision and affirmed legislature’s grant of mandatory transfer to common pleas)
- State v. Iacona, 93 Ohio St.3d 83 (Ohio 2001) (probable cause for bindover requires credible evidence of every element; more than suspicion but less than proof beyond a reasonable doubt)
- In re A.J.S., 120 Ohio St.3d 185 (Ohio 2008) (bindover probable‑cause determination reviewed de novo as a question of law)