State v. Jordan, 2023 Ohio 311

Defendant Tony Jordan was 15 and under juvenile-court supervision when he and accomplices committed armed street robbery and a home invasion targeting a 42‑year‑old and a 69‑year‑old, during which vehicles and valuables were stolen and a firearm was used.
Jordan was arrested after a vehicle chase and K‑9 tracking; cases proceeded in juvenile court with separate case numbers and an amenability hearing under R.C. 2152.12.
The juvenile court found Jordan not amenable to juvenile rehabilitation and transferred the matters to the general division; Jordan pleaded guilty to robbery, two counts of grand theft, and aggravated robbery with a one‑year firearm specification.
The trial court imposed an aggregate indefinite sentence of five to seven years under the Reagan Tokes framework.
On appeal Jordan (1) renewed a constitutional challenge to the Reagan Tokes non‑life indefinite sentencing structure and (2) argued the juvenile court abused its discretion in relinquishing jurisdiction—asserting an expert opinion and available juvenile detention time made him amenable.
The Eighth District affirmed: it summarily rejected the Reagan Tokes constitutional challenge per State v. Delvallie and upheld the transfer, finding competent, credible evidence supported the juvenile court’s weighing of R.C. 2152.12(D)/(E) factors and that the expert opinion was not dispositive.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Constitutionality of Reagan Tokes sentencing structure	State: Delvallie controls; similar constitutional challenges are rejected	Jordan: structure violates separation of powers, due process, and jury trial rights	Court: Overruled Jordan’s constitutional challenge; followed Delvallie and affirmed rejection
Juvenile transfer under R.C. 2152.12(B)(3) — abuse of discretion	State: Juvenile court properly weighed R.C. 2152.12(D)/(E) factors; competent, credible evidence supported transfer (victim trauma, use of firearm, prior juvenile supervision, failed prior rehabilitation, maturity, lack of sufficient time for juvenile rehabilitation)	Jordan: An expert opined he was amenable and juvenile system had programs and sufficient time (~5 years) for rehabilitation; therefore transfer was unreasonable	Court: No abuse of discretion; juvenile court considered the expert but permissibly gave greater weight to other statutory factors and identified a rational, factual basis for transfer

State v. Delvallie, 185 N.E.3d 536 (Ohio 2022) (rejecting constitutional challenges to the Reagan Tokes sentencing structure)
In re A.J.S., 897 N.E.2d 629 (Ohio 2008) (explaining juvenile amenability review and statutory transfer framework)
Johnson v. Abdullah, 187 N.E.3d 463 (Ohio 2021) (defining abuse‑of‑discretion standard)
Middendorf v. Middendorf, 696 N.E.2d 575 (Ohio 1998) (competent, credible evidence suffices to uphold discretionary determinations)
State v. West, 856 N.E.2d 285 (Ohio Ct. App. 2006) (recognizing discretion and need for rational, factual basis in juvenile transfer decisions)