State v. Brookshire, 2014 Ohio 5368

Brookshire, a juvenile offender, was bound over to adult court for aggravated robbery with a firearm specification; adult convictions included other offenses, counts 7–8.
The appellate court previously reversed most of Brookshire’s convictions and sentences, except the aggravated-robbery-with-firearm-specification conviction.
The State urged that counts 7–8 remained mandatory bindovers and thus not subject to a reverse bindover under R.C. 2152.121, even after dismissal of firearm specifications.
R.C. 2152.121 outlines three paths for bindover depending on whether the juvenile offense would be mandatory, discretionary, or not bindover at all in juvenile court.
Brookshire argued counts 7–8 could be construed as complicity charges, which would not satisfy mandatory bindover under R.C. 2152.10(A)(2)(b).
The court granted reconsideration, vacated its prior judgment, and amended the decision to affirm counts 7–8.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether counts 7–8 were subject to reverse bindover notwithstanding firearm-specification dismissal	State argued mandatory bindover remained due to counts' firearm allegations	Brookshire argued dismissal of firearm specs could negate mandatory bindover	Counts 7–8 affirm bindover; reverse not required

State v. Brookshire, 2014-Ohio-4858 (Ohio 2014) (reconsideration and bindover discussion in the appellate decision)
State v. Hanning, 89 Ohio St.3d 86 (Ohio 2000) (complicity vs. principal offense and bindover implications)
State v. Strub, 48 Ohio App.2d 57 (7th Dist. 1975) (accomplice versus principal offender charging)