State v. Amos, 2016 Ohio 1319

Amos (15) and co-defendants used fake Craigslist ads to lure buyers and commit armed robberies on March 25–28, 2014; victims reported similar modus operandi.
Undercover police arranged a sting on March 28; Shearer entered an undercover officer’s car with a gun pointed at his head, shots were fired, Shearer was wounded, and Amos was found nearby with a loaded gun, cocaine, and a victim’s stolen cell phone.
Juvenile court held a probable-cause hearing, ordered a social/mental-health investigation, then held an amenability hearing and transferred (discretionary bindover) Amos to common pleas, finding he was not amenable to juvenile rehabilitation.
Grand jury indicted Amos on multiple counts; Amos pleaded guilty in common pleas to three aggravated robberies with one-year firearm specifications and one gun-in-vehicle count; other counts were dismissed by plea.
Trial court imposed an aggregate prison term of seven years. Amos appealed, challenging (1) sufficiency of evidence for probable cause on the aggravated robbery of Sergeant Owen, and (2) the juvenile court’s amenability determination.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Probable cause for aggravated robbery (Sergeant Owen)	State: evidence (victim testimony, co-defendant admissions, undercover operation, weapons recovered) showed substantial steps and probable cause that Amos was complicit in an attempted robbery.	Amos: no completed theft or verbal demand occurred; Shearer never asked for money or took property, so no theft/attempt.	Court: Overruled Amos — substantial-step/attempt doctrine and the facts (entry with gun, brandishing, coordinated plan) supplied probable cause.
Juvenile amenability for discretionary bindover	State: factors (serious, organized repeated armed robberies; danger to community; Amos’s role as “muscle”; presence of gun/drugs) support transfer to adult court.	Amos: juvenile factors (age, no prior delinquencies, stable home, potential for rehabilitation) outweigh transfer; court overemphasized offense severity.	Court: No abuse of discretion — court considered required factors, relied on investigation report and record, and reasonably concluded Amos was not amenable.
Waiver by guilty plea of bindover challenge	State: cites Quarterman to argue challenges may be forfeited after plea.	Amos: challenges to bindover affect subject-matter jurisdiction and are not waived by guilty plea; appellate review preserved.	Court: Quarterman inapplicable; appellate precedent permits review of bindover despite guilty plea because issue concerns common pleas court jurisdiction.

In re M.P., 923 N.E.2d 584 (Ohio 2010) (procedures for discretionary juvenile bindover and required investigation/hearing)
In re A.J.S., 897 N.E.2d 629 (Ohio 2008) (probable-cause standard for juvenile bindover and elements for aggravated robbery)
State v. Quarterman, 19 N.E.3d 900 (Ohio 2014) (forfeiture of constitutional challenges after guilty plea; discussed but deemed inapposite)
State v. Golphin, 692 N.E.2d 608 (Ohio 1998) (juvenile-court original jurisdiction and bindover principles)
State v. Kirkland, 15 N.E.3d 818 (Ohio 2014) (criminal-attempt substantial-step standard)
State v. Woods, 357 N.E.2d 1059 (Ohio 1976) (substantial-step and corroboration of criminal purpose for attempt)
State v. Group, 781 N.E.2d 980 (Ohio 2002) (substantial-step standard allows police intervention to prevent completion of crime)
State v. Wilson, 652 N.E.2d 196 (Ohio 1995) (bindover defects affect subject-matter jurisdiction and survive guilty plea)
Gaskins v. Shiplevy, 656 N.E.2d 1282 (Ohio 1995) (challenge to bindover surviving guilty plea because it concerns jurisdiction)