State v. Hand, 2014 Ohio 3838

Hand was convicted of aggravated burglary, aggravated robbery, felonious assault, and a firearm specification in the trial court.
Hand had a prior delinquency adjudication for aggravated robbery, treated as a prior conviction for sentencing purposes.
The trial court imposed an aggregate six-year sentence: three concurrent years for the substantive offenses and three additional years for the firearm specification.
The court relied on R.C. 2929.13(F)(6) and considered the delinquency adjudication as a basis for mandatory prison time.
Hand argued that using a juvenile adjudication to create a mandatory term violated due process and Apprendi.
The intermediate appellate court majority upheld the use of the delinquency adjudication as a prior conviction; the dissent would reverse for due process concerns.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether using a delinquency adjudication as a prior conviction violates due process and Apprendi	Hand argues it violates due process and Apprendi by lacking jury adjudication and indictment notice.	Hand's position is rejected; the delinquency adjudication falls within Apprendi's prior-conviction exception per Craver and related authorities.	No due process violation; equal to prior conviction for sentencing.

State v. Craver, 2014-Ohio-3635 (2d Dist. Montgomery 2014) (delinquency adjudication treated as prior conviction upheld)
State v. Parker, 2012-Ohio-4741 (8th Dist. Cuyahoga 2012) (supports treating delinquency adjudication as prior conviction under Apprendi)
State v. Adkins, 129 Ohio St.3d 287, 2011-Ohio-3141 (Ohio 2011) (delinquency adjudication can count toward penalty enhancements in certain contexts)
Alleyne v. United States, 133 S. Ct. 2151 (U.S. 2013) (extends Apprendi to mandatory-minimum penalties)
Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (mandatory enhancements require jury findings)