State v. Blevins
2017 Ohio 8225
| Ohio Ct. App. | 2017Background
- In March 2014, 17-year-old Karlos Blevins fired a gun at a dance; the shooting resulted in the death of a 15‑year‑old.
- Under Ohio’s mandatory bindover statutes (R.C. 2152.10(A)(2)(b) and 2152.12(A)(1)(b)), the juvenile court transferred Blevins’ case to the general division of the Cuyahoga County Court of Common Pleas.
- A grand jury indicted Blevins on aggravated murder, murder, felonious assault, grand theft, tampering with evidence, and aggravated rioting, many with firearm and gang specifications.
- Blevins pleaded guilty to aggravated murder with one‑ and three‑year firearm specifications and to tampering with evidence; other counts and gang specifications were dropped.
- He was sentenced to 23 years to life on aggravated murder plus consecutive one‑ and three‑year firearm terms and concurrent three years for tampering.
- On appeal, Blevins challenged the constitutionality of mandatory bindover, arguing it violated state and federal due process; the appellate court disposed of the claim in light of the Ohio Supreme Court’s subsequent decision in State v. Aalim (Aalim II).
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether mandatory bindover statutes violate due process | State: statutes are constitutional and rationally related to public safety | Blevins: mandatory bindover denies due process by eliminating juvenile amenability review | The court, relying on Aalim II, held mandatory bindover complies with Ohio and U.S. due process and equal protection |
| Whether juvenile defendants have a substantive due‑process right to an amenability hearing | State: no substantive right exists because juvenile courts and amenability hearings are statutory developments | Blevins: amenability hearing is required as a due‑process safeguard before adult transfer | Court held substantive due process does not require amenability hearings; such proceedings are not deeply rooted in history/tradition |
| Whether remand for an amenability hearing was required | State: no remand necessary under Aalim II | Blevins: case should be remanded for amenability determination | Court denied remand and affirmed transfer and conviction |
| Whether mandatory bindover violates separation of powers by intruding on legislative authority to define jurisdiction | State: bindover reflects legislative judgment permitting general‑division jurisdiction over certain juveniles | Blevins: juvenile court discretion should override legislature’s grant of jurisdiction | Court accepted Aalim II’s reasoning that enforcing legislative jurisdiction is proper; no constitutional infirmity |
Key Cases Cited
- Moore v. East Cleveland, 431 U.S. 494 (1977) (discussing historical roots required for substantive‑due‑process protections)
- Palko v. Connecticut, 302 U.S. 319 (1937) (framework for determining fundamentals implicit in ordered liberty)
- State v. Fitzpatrick, 102 Ohio St.3d 321 (2004) (a guilty plea admits factual guilt but does not waive subject‑matter jurisdiction challenges)