State v. Martin, 209 N.E.3d 688

A juvenile (Martin) was accused in a shooting that killed Darnez Canion; police found multiple shell casings and security video showing Martin with a gun near where casings were recovered.
A witness (M.G.) watched part of the incident via a FaceTime call and reported seeing shots from Martin’s vicinity but later conceded uncertainty about whether Martin’s gun fired.
The state filed delinquency charges including involuntary manslaughter; Ohio law requires mandatory bindover to adult court for certain firearm-related homicides if the juvenile court finds probable cause.
The juvenile court held a probable-cause hearing, found probable cause, and transferred Martin’s case to the general division; Martin was later indicted and pleaded guilty.
On appeal Martin argued the juvenile-court probable-cause finding was not supported by sufficient evidence and was against the manifest weight of the evidence; the court of appeals affirmed.
The Ohio Supreme Court considered whether a juvenile-court probable-cause bindover determination is reviewable under the manifest-weight standard.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a juvenile court’s probable-cause determination at a mandatory bindover hearing is subject to manifest-weight review on appeal	State: probable-cause finding should be reviewed for legal sufficiency/deference to court’s credibility assessments but not by manifest-weight standard	Martin: the juvenile-court probable-cause finding should be subject to manifest-weight review (weighing credibility and conflicting evidence)	The court held: No. Probable-cause determinations at bindover are not subject to manifest-weight review; they are a gatekeeping, preliminary inquiry requiring sufficient credible evidence and are not a trial-level weighing of the greater amount of evidence. Probable-cause review is distinct and deferential credibility assessments do not convert it into manifest-weight review.

Maryland v. Pringle, 540 U.S. 366 (2003) (probable cause concerns assessment of probabilities)
Brinegar v. United States, 338 U.S. 160 (1949) (probable cause requires reasonable grounds for belief of guilt)
Illinois v. Gates, 462 U.S. 213 (1983) (probable cause is a fluid, common-sense concept)
Alabama v. White, 496 U.S. 325 (1990) (probable cause depends on content and reliability of information)
State v. Iacona, 93 Ohio St.3d 83 (2001) (state must present credible evidence of every element to support probable cause for bindover)
In re A.J.S., 120 Ohio St.3d 185 (2008) (juvenile court is gatekeeper; credibility assessments for probable cause are entitled to deference but not full trial weighing)
Eastley v. Volkman, 132 Ohio St.3d 328 (2012) (defines manifest-weight standard as appellate weighing of greater amount of credible evidence)
State v. Thompkins, 78 Ohio St.3d 380 (1997) (manifest-weight review concerns the persuasive weight of the evidence)