In re T.C., 2017 Ohio 123

Juvenile T.C. was charged in Dec. 2014 with rape of his nephew L.C. allegedly occurring Nov./Dec. 2012, when T.C. was 14–15 and L.C. was 4–5.
Court found L.C., under age 10 at proceeding, competent to testify after a competency hearing.
At the adjudicatory hearing, L.C. testified that T.C. instructed him to touch and orally engage T.C.’s genitals; L.C. identified body parts on a diagram and described the conduct.
Mother and a detective corroborated the report timeline; no physical evidence was collected due to the delay in reporting.
Defense witnesses (T.C., grandmother) denied any occasion when T.C. was alone with L.C. and challenged aspects of L.C.’s account and memory of events.
Trial court found T.C. delinquent for rape, committed him to DYS for at least 12 months (potentially until age 21), and classified him a Tier II sex offender.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency and weight of evidence supporting rape adjudication	State: L.C.’s testimony, if believed, established each element of R.C. 2907.02(A)(1)(b) (sexual conduct with a person under 13) and supports adjudication	T.C.: L.C. and Mother were not reliable; inconsistencies, delayed reporting, and alternative explanations undermine proof beyond a reasonable doubt	Court: Evidence was sufficient; credibility determinations favored L.C. and Mother, and the adjudication was not against the manifest weight of the evidence

State v. Thompkins, 78 Ohio St.3d 380 (1997) (discusses standard for reviewing manifest weight and sufficiency of the evidence)
State v. Jenks, 61 Ohio St.3d 259 (1991) (establishes the standard of review for sufficiency of the evidence in criminal cases)
State v. Martin, 20 Ohio App.3d 172 (1983) (articulates the approach for manifest-weight review)