State v. Loveless, 2019 Ohio 4830

In May 2006, when he was 17, Paul Loveless used an admin account to access Great Oaks’ computer network, then emailed school tech director screenshots showing payroll and grade-access; he agreed to meet school officials and police and waived Miranda before admitting the access and demonstrating it.
Police later obtained consent from Loveless’s father to seize three family computers; forensic exams (June 2006–June 2007) uncovered deleted and active child‑pornography files on those machines, some deleted during a period Loveless was alone in his bedroom.
The investigation proceeded slowly; detectives compiled files and in 2009 gathered images for prosecutor review. Loveless turned 21 on July 31, 2009. A grand jury returned a 26‑count indictment on August 5, 2009.
In October 2009 Loveless pleaded guilty to one count tampering with evidence, one count pandering obscenity, and five counts unauthorized use of a computer; he received community control and restitution, later serving two years after supervision violations.
In July 2018 Loveless moved to vacate his conviction, arguing (1) preindictment delay violated due process and (2) the common pleas court lacked subject‑matter jurisdiction because the offenses were committed while he was a juvenile; the trial court denied relief, and Loveless appealed.

Issue	Plaintiff's Argument (Loveless)	Defendant's Argument (State)	Held
Whether the common pleas court lacked subject‑matter jurisdiction under R.C. 2151.23(I) because offenses were committed while Loveless was <18	Loveless: He was effectively "taken into custody" or "apprehended" before turning 21 when police questioned him at school and thereafter, so juvenile court retained exclusive jurisdiction	State: Loveless was neither taken into custody (no arrest, no court order, no lawful physical detention) nor "apprehended" (no juvenile complaint/summons served) before he turned 21; R.C. 2151.23(I) therefore allowed prosecution in adult court after age 21	Court: Affirmed state — Loveless was not "taken into custody" or "apprehended" before 21, so common pleas had jurisdiction under R.C. 2151.23(I)
Whether preindictment delay violated due process and requires vacatur	Loveless: Excessive multi‑year delay before indictment prejudiced him and violated due process	State: Even if delay occurred, Loveless’s guilty plea waived any due‑process claim based on preindictment delay	Court: Guilty plea waived any challenge based on preindictment delay; claim fails

Bear v. Buchanan, 156 Ohio St.3d 348 (Ohio 2019) (explains R.C. 2151.23(I) divests juvenile court jurisdiction when specified conditions are met)
State v. Wilson, 73 Ohio St.3d 40 (Ohio 1995) (juvenile court’s exclusive subject‑matter jurisdiction cannot be waived)
State v. Walls, 96 Ohio St.3d 437 (Ohio 2002) (age at apprehension controls juvenile‑court jurisdiction; R.C. 2151.23(I) removes those over 21 from juvenile jurisdiction)
Wells Fargo Bank, N.A. v. Horn, 142 Ohio St.3d 416 (Ohio 2015) (a conviction is void if trial court lacks subject‑matter jurisdiction)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (custodial‑interrogation protections and waiver principles)
Rarey v. Schmidt, 115 Ohio St. 518 (Ohio 1926) (discusses lawful authority and physical detention in custody contexts)