State v. Martin
2016 Ohio 7764
Ohio Ct. App.2016Background
- Alexis Martin, a juvenile, was alleged to have participated in a planned burglary in which two victims were shot and one died.
- Juvenile court held an amenability hearing on the State’s motion to transfer; the court found Martin not amenable to juvenile rehabilitation and transferred (bound over) the case to common pleas court.
- Martin was indicted in common pleas court, initially pleaded not guilty, then moved to stay proceedings and to vacate the bindover claiming the juvenile court failed to consider R.C. 2152.021(F) (a diversion/abeyance provision for certain trafficking/victimization contexts).
- The trial court denied those motions; Martin then pleaded guilty to murder with a firearm specification and felonious assault pursuant to a plea agreement; other counts were dismissed and she was sentenced to 21 years to life.
- On appeal Martin argued (1) the juvenile court committed plain error by not considering R.C. 2152.021(F) and (2) that failure deprived the trial court of subject-matter jurisdiction, rendering convictions void.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether juvenile court’s failure to consider R.C. 2152.021(F) was jurisdictional | Martin: juvenile court’s omission deprived common pleas court of jurisdiction; convictions void | State: transfer complied with R.C. 2152.12; any alleged omission under §2152.021(F) is nonjurisdictional error | Court: transfer was proper under R.C. 2152.12; omission did not deprive common pleas court of jurisdiction — Martin’s jurisdictional challenge fails |
| Whether failure to consider R.C. 2152.021(F) was reviewable after guilty plea | Martin: appellate review of juvenile-court error allowed despite plea | State: guilty plea waived nonjurisdictional defects in prior proceedings | Court: Martin’s guilty plea waived nonjurisdictional challenges to juvenile-court errors; because she did not show the omission was jurisdictional or rendered her plea involuntary, error was waived |
Key Cases Cited
- State v. Wilson, 73 Ohio St.3d 40 (Ohio 1995) (juvenile court’s exclusive jurisdiction cannot be waived absent proper bindover)
- Gaskins v. Shiplevy, 74 Ohio St.3d 149 (Ohio 1995) (same principle regarding juvenile jurisdiction and bindover)
- State v. D.W., 133 Ohio St.3d 434 (Ohio 2012) (distinguishes mandatory vs. discretionary transfer and outlines bindover scheme)
- Wells Fargo Bank, N.A. v. Horn, 142 Ohio St.3d 416 (Ohio 2015) (example noting absence of proper juvenile bindover deprives common pleas court of jurisdiction)