State v. Aalim (Slip Opinion)
150 Ohio St. 3d 489
| Ohio | 2017Background
- In 2013 the State charged Matthew Aalim (age 16) with aggravated robbery and a firearm specification; the juvenile court held a probable-cause/age hearing and transferred him to adult court under R.C. 2152.10(A)(2)(b) and 2152.12(A)(1)(b).
- Aalim moved to dismiss the indictment, arguing mandatory bindover statutes violate due process and equal protection; the trial court denied the motion and he pled no contest and was sentenced.
- The Second District affirmed; this court initially reversed in State v. Aalim (Aalim I), holding mandatory bindover violated Ohio due process by requiring an amenability hearing.
- The State moved for reconsideration, arguing the court overlooked Article IV, §4(B) (the General Assembly’s exclusive authority to define common-pleas jurisdiction); the court granted reconsideration.
- On reconsideration the court vacated Aalim I and held that mandatory bindover under R.C. 2152.10(A)(2)(b) and 2152.12(A)(1)(b) does not violate the Due Course of Law/Due Process or Equal Protection clauses of the Ohio and U.S. Constitutions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandatory bindover violates substantive due process / creates a constitutional right to an amenability hearing | Aalim: youth requires individualized amenability hearing; irrebuttable transfer is fundamentally unfair | State: no substantive right exists; juvenile procedures provided (notice, counsel, hearing on age/probable cause) satisfy due process | No substantive due-process right to an amenability hearing; historical/tradition test not met; mandatory bindover upheld |
| Whether the mandatory-bindover procedure satisfies procedural due process / "fundamental fairness" | Aalim: limited hearing (age + probable cause) is inadequate under Mathews/Kent; risk of erroneous deprivation is high | State: hearing with counsel, parent, and written findings satisfies Kent and fundamental fairness | Court: procedural protections here met (hearing, counsel, findings); transfer did not violate fundamental fairness |
| Whether juveniles are a suspect class or possess a fundamental right triggering strict scrutiny for equal-protection review | Aalim: juveniles are similarly situated but treated differently by age-based automatic transfer; juveniles should be treated as a suspect class or protected by a fundamental right to amenability | State: age is not a suspect classification; no fundamental right at stake; rational-basis review applies | Juveniles are not a suspect class and have no fundamental right to an amenability hearing; statutes survive rational-basis scrutiny |
| Whether the Court erred in Aalim I by failing to account for Article IV, §4(B) (legislative authority over common-pleas jurisdiction) | State: Aalim I improperly gave juvenile judges veto power over legislature’s jurisdictional allocation | Aalim: (implicit) constitutional protections override statutory allocation | Court: Aalim I failed to consider §4(B); granting reconsideration, vacated Aalim I and affirmed trial-court judgment |
Key Cases Cited
- State v. Aalim, 150 Ohio St.3d 463 (Ohio 2016) (initial decision holding mandatory bindover unconstitutional; vacated on reconsideration)
- Kent v. United States, 383 U.S. 541 (U.S. 1966) (bindover hearing must include counsel and statement of reasons; transfer proceedings are critically important)
- In re Gault, 387 U.S. 1 (U.S. 1967) (juveniles are entitled to due process protections)
- Miller v. Alabama, 567 U.S. 460 (U.S. 2012) (juvenile sentencing requires consideration of youth; recognizing differences between juveniles and adults)
- Roper v. Simmons, 543 U.S. 551 (U.S. 2005) (juveniles’ diminished culpability relevant to constitutional limits on punishment)
- J.D.B. v. North Carolina, 564 U.S. 261 (U.S. 2011) (age must be considered in custody/Miranda analysis)
- Mathews v. Eldridge, 424 U.S. 319 (U.S. 1976) (balancing test for what process is due)
- Washington v. Glucksberg, 521 U.S. 702 (U.S. 1997) (framework for substantive-due-process analysis grounded in history and tradition)
- McKeiver v. Pennsylvania, 403 U.S. 528 (U.S. 1971) (due-process/fundamental fairness standard in juvenile proceedings)
- State v. Hanning, 89 Ohio St.3d 86 (Ohio 2000) (describing mandatory-bindover as a narrow legislative exception and context of rising juvenile crime)