State v. Hudson, 2020 Ohio 3577

Mahoning C.P. charged Frankie Hudson with six counts from two incidents: Counts 1–3 (first incident) and Counts 4–6 (second incident). The first incident occurred when Hudson was 17; the second when he was 18.
The court severed the incidents; Hudson pleaded guilty to Count 6 and was acquitted on Counts 4–5 after trial.
The State dismissed Counts 1–3 in the 2013 indictment and refiled identical Counts 1–3 in a new 2015 indictment, adding gang specifications and other charges; Hudson was 22 at reindictment/service.
Hudson moved to dismiss the 2015 indictment for lack of subject-matter jurisdiction, arguing the offenses occurred when he was 17 and therefore fell within juvenile-court jurisdiction under R.C. 2151.23 and 2152.02.
The trial court denied the motion; this court denied a writ of prohibition; Hudson later entered a plea agreement and was sentenced to 15 years; he appealed the denial of the motion to dismiss.
The Seventh District held the general division had jurisdiction because Hudson was not apprehended for the juvenile-era felonies until after age 21, so juvenile jurisdiction did not apply under R.C. 2152.02(C)(3) / 2151.23(I).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the common pleas general division had subject-matter jurisdiction over Counts 1–3 (offenses committed at age 17)	Hudson was not apprehended for those acts until he was 22 (service of 2015 indictment), so juvenile court lacks jurisdiction under R.C. 2152.02(C)(3) / 2151.23(I)	Hudson was effectively apprehended when originally indicted in 2013 (age 20), so juvenile court should have retained jurisdiction for acts committed at 17	Court: General division has jurisdiction; dismissal/refiling did not create a jurisdictional defect; assignment of error overruled

None: the opinion primarily relies on Ohio statutory provisions and cited only unpublished/slip appellate decisions without official reporter citations.