State ex rel. Jean-Baptiste v. Kirsch, 134 Ohio St. 3d 421

Jean-Baptiste, born 1989, was adjudicated delinquent for a 2006 rape committed as a minor and committed to DYS in 2007 with a fixation to 21st birthday.
Disposition in 2007 placed him in a secure facility with a minimum term and ordered sex-offender registration upon release.
He was released on his 21st birthday, January 18, 2010, and later faced a juvenile-offender classification hearing scheduled for February 8, 2010.
The juvenile court issued the dispositional order and committed him to DYS; it later sought to classify him as a juvenile-offender registrant.
Jean-Baptiste sought a writ of prohibition to stop the classification hearing, arguing the court lacked jurisdiction to classify after turning 21.
The court of appeals denied the writ, and this Court granted review to determine whether the juvenile court patently and unambiguously lacked jurisdiction to proceed with the classification hearing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the juvenile court patently and unambiguously lacks jurisdiction to classify after 21.	Jean-Baptiste asserts lack of jurisdiction since he turned 21 before hearing.	Kirsch contends continuing jurisdiction allows the hearing.	Yes; juvenile court patently and unambiguously lacks jurisdiction.

In re Cross, 96 Ohio St.3d 328 (2002-Ohio-4183) (limits on juvenile court jurisdiction after release from custody in delinquency cases)
N.A. v. Cross, 125 Ohio St.3d 6 (2010-Ohio-1471) (delinquency proceedings after age 21; jurisdiction continues for certain classifications)
In re J.V., 134 Ohio St.3d 1 (2012-Ohio-4961) (addressed juvenile classification/authorization issues in the context of 21-year-old status)
State v. Bellman, 86 Ohio St.3d 208 (1999-Ohio-714) (time provisions in juvenile proceedings are often directory, not jurisdictional)
In re D.J.S., 130 Ohio St.3d 257 (2011-Ohio-5342) (retroactivity context involving SB 10 and juvenile-offender provisions)