In re T.D.R., 2015 Ohio 3541

14-year-old appellant T.D.R. committed an armed robbery at a Sunoco on July 10, 2014, using a BB gun; he was apprehended nearby.
Charged with robbery (second-degree felony if adult) and obstruction (misdemeanor), with an offense-of-violence and SYO specification; pleaded guilty.
At disposition the juvenile court imposed a blended serious-youthful-offender (SYO) sentence: a four-year adult prison term stayed, commitment to DYS for 1 year to maximum until age 21, 90 days juvenile detention, and placement at a Community Correctional Facility (CCF); adult term stayed pending successful completion of juvenile dispositions.
Appellant appealed, arguing the court abused its discretion by imposing the discretionary SYO adult sentence without properly considering statutory factors in R.C. 2152.13(D)(2)(a).
The State argued the issue was not ripe because the adult sentence was stayed and hypothetical unless the juvenile failed the juvenile disposition.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court abused its discretion or acted contrary to law by imposing a discretionary SYO adult sentence without required on-the-record findings	T.D.R.: trial court failed to properly consider/statutorily-required factors before imposing SYO adult sentence; four-year adult term inappropriate given age and circumstances	State: appeal is not ripe because the adult sentence is stayed and hypothetical until juvenile disposition fails	Court affirmed: appeal is ripe under R.C.2152.13(D)(3); trial court made on-the-record findings (nature/circumstances, history, available juvenile programming) and complied with statutory requirements for a discretionary blended SYO sentence; stay of adult term proper

State v. D.H., 120 Ohio St.3d 540 (Ohio 2009) (explains blended SYO disposition and standards for imposing/staying adult portion)
State v. Ferranto, 112 Ohio St. (Ohio 1925) (abuse of discretion standard: court abuses discretion when judgment does not comport with reason or the record)