State v. C.J., 110 N.E.3d 50

14-year-old appellant C.J. and 15-year-old B.N. played a physical one-on-one basketball game at a community center; fouls escalated and B.N. was injured earlier in the game.
Minutes before the altercation, center video (later recorded over) showed B.N. throw a ball at a friend and shove another boy on a bench. Parties stipulated to that portion of the video’s contents.
At the end of the game C.J. knocked B.N. down, taunted him; as B.N. left the court he pushed C.J. and (disputed) kicked him. C.J. punched B.N., causing visible injury.
Officer Stafford interviewed C.J. (with C.J.’s mother present) without Miranda warnings; C.J. gave a written statement and left. No arrest at that time.
Defense requested preservation of the community center video; police/community center recorded over it in the normal course. Defense moved to dismiss for spoliation and to suppress statements for Miranda violations; the juvenile magistrate denied both and later adjudicated C.J. delinquent of disorderly conduct (lesser included) rejecting his self-defense claim.
On appeal the court reviewed (1) whether failure to preserve the video violated due process, (2) whether the pre-arrest interview required Miranda warnings, and (3) sufficiency/manifest weight of evidence regarding disorderly conduct and self-defense.

Issue	State's Argument	C.J.'s Argument	Held
Whether failure to preserve community-center video required dismissal for violating due process	Video was not materially exculpatory and comparable evidence existed (stipulation, witnesses, officer testimony).	Video was materially exculpatory because it would show B.N.’s angry state and tend to prove C.J.’s claim of self-defense.	Denied: video was not materially exculpatory; comparable evidence was available, so no due-process violation.
Whether statements to Officer Stafford should be suppressed for lack of Miranda warnings	Interview was noncustodial, on-scene fact-finding; Miranda not required.	C.J. was not free to leave and thus was in custody, so Miranda warnings were required.	Denied: interview was noncustodial (mother present, public bench, officer did not restrain or arrest), so Miranda warnings not required.
Whether evidence supports delinquency adjudication for disorderly conduct and rejects self-defense	State: evidence supports reckless, intentional punch causing injury; self-defense not proven by preponderance.	C.J.: acted reflexively/instinctively and in self-defense after being shoved and kicked.	Affirmed: trier of fact credited State’s witnesses; C.J. failed to prove self-defense and acted recklessly.

Miranda v. Arizona, 384 U.S. 436 (establishes custodial-interrogation Miranda rule requiring warnings)
State v. Benton, 136 Ohio App.3d 801 (discusses burden-shifting when requested evidence is destroyed in normal course)
State v. Biros, 78 Ohio St.3d 426 (Miranda applies only to custodial interrogation)
State v. Williford, 49 Ohio St.3d 247 (self-defense burden and limits on force that can be used)