In re T.M., 78 N.E.3d 349

Appellant T.M., age 17 at the time, pleaded true to two counts of gross sexual imposition involving victims aged 9 and 10; other counts were dismissed. She was adjudicated delinquent and committed to DYS until her 21st birthday.
At disposition the court set a juvenile-offender-registrant classification hearing to occur before T.M.’s discharge from DYS.
At the November 20, 2015 classification hearing T.M. objected on Equal Protection, Due Process, and Double Jeopardy grounds to mandatory registration under R.C. 2152.83(A).
The trial court classified T.M. as a Tier II juvenile sex offender under R.C. 2152.83(A), requiring in-person registration every 180 days for 20 years.
On appeal T.M. raised two assignments of error: (1) that mandatory registration for 16–17 year olds under R.C. 2152.83(A) violates Equal Protection; and (2) that imposition of registration extending beyond juvenile-court jurisdiction violates the Eighth and Fourteenth Amendments and Ohio constitutional provisions.
The appellate court affirmed: it rejected the due process/cruel-and-unusual-punishment challenge (relying on In re D.S.) and rejected the equal protection challenge under rational-basis review.

Issue	Plaintiff's Argument (T.M.)	Defendant's Argument (State)	Held
Whether mandatory registration for 16–17 year-olds under R.C. 2152.83(A) violates Equal Protection	R.C. 2152.83(A) treats similarly situated juveniles differently solely by age (mandatory for 16–17, discretionary for 14–15) without a rational basis	Legislature may rationally differentiate by age because older juveniles are closer to adulthood, less responsive to treatment, and pose greater public-safety concerns	Affirmed: statute passes rational-basis review; no Equal Protection violation
Whether imposing registration duties that extend beyond juvenile-court jurisdiction violates Due Process / Eighth Amendment	Registration period extending past juvenile jurisdiction denies fundamental fairness and constitutes cruel and unusual punishment	In re D.S. holds juvenile registration statutes with periodic review provide sufficient procedural protections and are consistent with rehabilitative goals	Affirmed: Due Process challenge rejected; statute includes adequate procedural protections and periodic-review mechanism

In re D.S., 146 Ohio St.3d 182 (Ohio 2016) (upheld juvenile registration with review as satisfying due-process and rehabilitative concerns)
State v. Thompkins, 75 Ohio St.3d 558 (Ohio 1996) (party challenging statute bears burden to prove unconstitutionality)
McCrone v. Bank One Corp., 107 Ohio St.3d 272 (Ohio 2005) (equal protection analysis requires similarly situated individuals be treated similarly)
Groch v. Gen. Motors Corp., 117 Ohio St.3d 192 (Ohio 2008) (rational-basis review where classification does not affect fundamental right or suspect class)
State v. Ferraiolo, 140 Ohio App.3d 585 (Ohio Ct. App.) (presumption of legislative constitutionality)
Vacco v. Quill, 521 U.S. 793 (U.S. 1997) (burden on challenger to show a law is not rationally related to a legitimate interest)