In re T.L., 2014 Ohio 1840

In June 2008, T.L., age 16, admitted to two counts of aggravated robbery with firearm and SYO specifications and agreed to a three-year ODYS commitment; plea hearing referenced a possible 10-year adult term if the adult portion were invoked.
June 19, 2008 journal entries adjudged delinquent, committed to ODYS (one year per count plus firearm specification consecutively); no appeal filed.
January 23, 2009 nunc pro tunc entry recited a 10-year minimum adult term stayed pending successful completion of the juvenile disposition; no appeal filed.
May 11, 2011 juvenile court granted the state's motion to invoke the adult portion of the SYO disposition and committed T.L., then 19, to adult prison; no appeal filed.
May 16, 2013, after turning 21, T.L. filed a motion to vacate a void sentence; the juvenile court denied it and T.L. appealed.

Issue	Plaintiff's Argument (T.L.)	Defendant's Argument (State/Juvenile Court)	Held
Whether the juvenile court could entertain T.L.’s 2013 motion to vacate a void SYO sentence after T.L. turned 21	The adult portion was void or imposed without proper notice and was based on conduct before a valid SYO disposition; court should vacate the sentence	Juvenile court lacked jurisdiction after the juvenile turned 21 to consider collateral attacks on the SYO adult portion	Held: Juvenile court lacked jurisdiction to consider the 2013 motion; appeal on merits barred
Whether trial counsel was ineffective for failing to object to imposition of the adult SYO term	Counsel should have objected in 2011; failing to do so deprived T.L. of relief	Ineffective assistance claim is barred by res judicata and the time limits for postconviction relief	Held: Claim barred by res judicata and statutory time limits; assignment overruled

In re J.V., 134 Ohio St.3d 1, 979 N.E.2d 1203 (Ohio 2012) (juvenile court loses jurisdiction over adjudicated delinquents once they turn 21; dispositions entered after that point are void)