State v. Ferguson
2017 Ohio 7930
| Ohio Ct. App. | 2017Background
- In June 2014, 16‑year‑old Darryl Ferguson struck 35‑year‑old Ryan Adams after Adams made sexually suggestive comments to Ferguson’s mother and sister; Adams was rendered unconscious, later died from blunt head trauma, and Ferguson was later charged.
- Juvenile court: murder charge was transferred to adult court under mandatory transfer; felonious assault was later transferred under discretionary transfer after an amenability hearing.
- Ferguson was arrested following two interviews on June 10, 2014; he waived Miranda rights and gave written and oral statements.
- Bench trial (Feb 2016): court found Ferguson guilty of aggravated assault and voluntary manslaughter (inferior offenses), merged counts, and sentenced him to an 11‑year mandatory term under R.C. 2929.13(F) based on a prior juvenile adjudication.
- Ferguson appealed, raising five issues: (1) use of juvenile adjudication to trigger mandatory sentence; (2) suppression of statements as product of unlawful arrest; (3) imposition of maximum sentence; (4) failure to follow R.C. 2152.121 “reverse bindover” procedures; (5) juvenile court’s amenability finding.
Issues
| Issue | State's Argument | Ferguson's Argument | Held |
|---|---|---|---|
| Juvenile amenability / bindover (discretionary) | Juvenile court’s amenability ruling was valid and supports transfer of felonious assault | Juvenile court abused discretion in finding Ferguson not amenable | Court: mandatory transfer of murder required; discretionary transfer on related felonious assault was moot but, alternatively, amenability ruling was not an abuse of discretion |
| Suppression of June 10 statements | Statements admissible: Ferguson voluntarily went to station, was Mirandized, and his statements were not fruits of illegal arrest | Officers effectively arrested/detained Ferguson without probable cause; statements should be suppressed as fruit of unlawful arrest | Court found officers credible, Ferguson voluntarily accompanied officers, Miranda warnings valid; suppression denied (waived challenge to post‑first‑interview detention) |
| Use of prior juvenile adjudication to impose mandatory sentence | Hand exception not retroactive to avoid remand? (State accepted Hand altered mandatory status but argued no resentencing needed) | Relying on juvenile adjudication to make sentence mandatory violates Hand and due process | Court: Hand applies; sentence mandatory status improper — remand for resentencing |
| Imposition of maximum sentence (11 yrs) | Trial court considered statutory factors; discretion to impose maximum within range | Maximum excessive given youth/maturity; trial court should explain | Court: sentence not contrary to law and supported by record; assignment overruled (but overall sentence reversed for other reasons) |
| Reverse bindover / R.C. 2152.121 compliance | No reverse bindover required because juvenile court already held amenability hearing for felonious assault | Mandatory transfer applied only to murder; voluntary manslaughter conviction was not a mandatory‑transfer offense so adult court had to stay sentence and transfer under R.C. 2152.121(B)(3) | Court: R.C. 2152.121 applies; adult court erred by not staying sentence and remanding to juvenile court — assignment sustained; remand required |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (custodial interrogation/Miranda warnings requirement)
- Berkemer v. McCarty, 468 U.S. 420 (reasonable‑person test for custody analysis)
- New York v. Harris, 495 U.S. 14 (preexisting probable cause and admissibility of statements)
- State v. Hand, 149 Ohio St.3d 94 (Ohio Supreme Court: juvenile adjudications cannot be used as prior convictions to enhance adult sentences)
- State v. Retherford, 93 Ohio App.3d 586 (trial court as factfinder on suppression rulings)