Background - Ronald Amos was adjudicated delinquent in 2010 for conduct equivalent to adult rape, committed to DYS, released March 30, 2011, and at that time was classified as a Tier I juvenile-offender registrant and placed on parole. - Amos completed parole and was discharged on June 24, 2013; no completion-of-disposition (R.C. 2152.84) hearing was held at that time. - On July 2, 2014 the juvenile court — after Amos’s discharge and without him present — held a completion-of-disposition hearing and ordered the prior Tier I classification remain in effect. - Amos was indicted (B-1503921) for failing to notify the sheriff of an address change; he moved to dismiss, arguing the juvenile court lacked authority to classify him after disposition was complete. - The common pleas court dismissed that indictment and later permitted Amos to withdraw a guilty plea in a separate case (B-1402018) and dismissed that indictment; the state appealed both rulings. - The appellate court affirmed, holding the juvenile court lacked authority to complete the mandatory classification process after Amos’s disposition had ended and therefore Amos had no duty to register under R.C. Chapter 2950. ### Issues | Issue | Plaintiff's Argument | Defendant's Argument | Held | |---|---:|---:|---| | Was a pretrial motion to dismiss the indictment a proper vehicle to challenge registration duty? | Palmer permits dismissal where indictment alleges violations by a person not subject to the law. | Amos argued he was not subject to registration so indictment was defective. | Yes — dismissal was appropriate because law did not apply if no duty to register. | | Could the juvenile court validly conduct the completion-of-disposition (R.C. 2152.84) hearing more than a year after Amos completed disposition? | State argued juvenile court retained power to review/confirm classification post-disposition. | Amos argued the court lost jurisdiction after discharge and the late hearing was void. | Court held the juvenile court lacked authority after disposition was completed; the July 2014 order was void. | | Did Amos demonstrate manifest injustice to withdraw his guilty plea for failing to notify an address change? | State argued plea was valid. | Amos argued he had no registration duty, so plea was not knowing/voluntary. | Yes — manifest injustice shown because underlying duty to register did not exist; plea withdrawal and dismissal were proper. | | Is the proper remedy to void a late review hearing or to seek other relief (e.g., compel hearing)? | State (dissent) argued jurisdiction continued and remedy would be to compel hearing or appeal notice, not to invalidate registration. | Amos sought to void the belated classification and consequent registration duty. | Majority applied precedent limiting juvenile-court jurisdiction post-disposition and invalidated the late classification; dissent would have allowed jurisdiction to continue. | ### Key Cases Cited State v. Palmer, 964 N.E.2d 406 (Ohio 2012) (Crim.R.12 dismissal appropriate where indictment alleges violations by person not subject to statute) State ex rel. Jean-Baptiste v. Kirsch, 983 N.E.2d 302 (Ohio 2012) (juvenile court lacks statutory authority to classify after disposition fully satisfied) In re Cross, 774 N.E.2d 258 (Ohio 2002) (completion of probation ends juvenile court's jurisdiction to make further dispositions on that count) In re D.S., 54 N.E.3d 1184 (Ohio 2016) (once an initial classification is made, juvenile court retains continuing authority to review classification) * State v. Schulze, 59 N.E.3d 673 (Ohio App. 2016) (post-disposition order applying wrong statutory scheme is void; required process must be followed)