State v. Lewis, 102 N.E.3d 1169

Jada Lewis was charged in juvenile court with contributing to the delinquency of a minor based on her fifth‑grade son's habitual truancy (19–20 unexcused absences in 2015–2016).
Lewis appeared pro se at arraignment, pretrial proceedings, and trial before a magistrate; the magistrate noted she had been advised of her right to counsel and proceeded with her pro se trial.
School witnesses testified no timely written excuses were received until the eve of trial; Lewis testified she sent notes with her "absent‑minded" son and occasionally called the school.
The magistrate found the child was a habitual truant and that Lewis contributed to his unruliness/delinquency; the trial court adopted the magistrate’s decision and imposed a sentence including 180 days confinement (120 suspended), a $25 fine, and probation.
On appeal Lewis raised (1) that the court failed to adequately inquire into a knowing, intelligent, voluntary waiver of counsel/self‑representation before imposing confinement, and (2) that the evidence was legally insufficient to prove she acted recklessly in failing to provide timely written excuses.
The court vacated the confinement portion of the sentence for inadequate waiver inquiry but affirmed the conviction and the non‑jail portions of sentence, finding sufficient evidence of recklessness.

Issue	Plaintiff's Argument (Lewis)	Defendant's Argument (State)	Held
Whether the court erred by imposing confinement without a proper inquiry into waiver of counsel/self‑representation	Magistrate’s general advisement and Lewis’ pro se appearance were insufficient to establish a knowing, voluntary waiver; confinement must be vacated	Procedure was inadequate; but conviction and non‑jail sanctions may stand	The court vacated the confinement portion (including suspended days) because a proper waiver inquiry was not made; conviction and other penalties remain
Whether the evidence was legally sufficient to show Lewis acted recklessly in failing to provide timely written excuses for absences	Her conduct was at most negligent (failure in due care) and not reckless; sending notes with the child shows lack of heedless indifference	Repeated school notices, a home visit, and no timely written excuses support an inference of recklessness	Evidence was sufficient—viewed in the light most favorable to the prosecution, a rational trier of fact could find Lewis acted recklessly; assignment of error overruled

State v. Moody, 104 Ohio St.3d 244, 819 N.E.2d 268 (Ohio 2004) (recklessness mens rea required for contributing to unruliness/delinquency under R.C. 2919.24)
State v. Jenks, 61 Ohio St.3d 259, 574 N.E.2d 492 (Ohio 1991) (standard for reviewing sufficiency of the evidence)
State v. Gans, 168 Ohio St. 174, 151 N.E.2d 709 (Ohio 1958) (distinguishes aiding/abetting vs. acting in a way tending to cause delinquency/unruliness)
State v. Hawn, 138 Ohio App.3d 449, 741 N.E.2d 594 (Ohio Ct. App.) (discusses sufficiency review and elements for similar offenses)