State v. Martin (Slip Opinion), 116 N.E.3d 127

Alexis Martin, 15 at the time, participated in a robbery/burglary of Angelo Kerney’s home; Kerney was killed and another victim severely injured. She was charged in juvenile court with multiple violent delinquency offenses and transferred to adult court.
The juvenile court found Martin had a "very clear history of human trafficking" (Kerney identified as a trafficker) but did not invoke or apply Ohio’s safe-harbor statute, R.C. 2152.021(F), nor appoint a guardian ad litem.
In adult court Martin pleaded guilty to aggravated murder (with firearm spec.) and felonious assault, reserving the right to challenge jurisdiction/transfer issues on appeal. She was sentenced to 21 years to life.
On appeal Martin argued the juvenile court was required to appoint a guardian ad litem and consider diversion under R.C. 2152.021(F)(1)(b) because her charged acts were “related to” her trafficking victimization.
The Supreme Court of Ohio: held the safe-harbor statute applies where charges are related to victimization (not limited to nonviolent offenses), but when no objection is made below plain-error review applies; Martin failed to show her violent offenses were "related to" the trafficking so she could not establish plain error. Judgment affirmed.

Issue	Plaintiff's Argument (Martin)	Defendant's Argument (State)	Held
Whether R.C. 2152.021(F)(3) required appointment of a guardian ad litem and a safe-harbor hearing before bindover where the juvenile was a human-trafficking victim	Juvenile court had reason to believe she was trafficked and the charged offenses related to that victimization, so the court was required to appoint a guardian ad litem and consider diversion	The safe-harbor provisions apply only to prostitution/solicitation (nonviolent) offenses and do not apply here	R.C. 2152.021(F)(1)(b) and (F)(3) apply when the court has reason to believe the juvenile was trafficked and the charged act is “related to” the victimization; statute is not limited to nonviolent offenses.
Effect of guilty plea and appropriate standard of review where juvenile court did not consider R.C. 2152.021(F) and no objection was raised	Martin argued the juvenile-court defect survived her adult guilty plea and required vacatur of the transfer	State argued defendant waived nonjurisdictional claims by pleading guilty in adult court; alternatively the court’s omission did not require reversal	When the juvenile court fails to consider/apply R.C. 2152.021(F) and no objection was made, criminal plain-error review (Crim.R. 52(B)) applies. Martin failed to show plain error because she did not demonstrate her charged offenses were "related to" her trafficking victimization, so reversal was not warranted.

Sears v. Weimer, 143 Ohio St. 312 (1944) (when statutory language is unambiguous, apply it as written)
State v. Wilson, 73 Ohio St.3d 40 (1995) (juvenile-court jurisdiction and bindover principles)
Dorrian v. Scioto Conservancy Dist., 27 Ohio St.2d 102 (1971) (the word "shall" is ordinarily mandatory)
State v. Barnes, 94 Ohio St.3d 21 (2002) (limitations of Crim.R. 52(B) plain-error review)
State v. Hill, 92 Ohio St.3d 191 (2001) (error definition and plain-error analysis)
United States v. Olano, 507 U.S. 725 (1993) (federal standard for plain-error review)
Goldfuss v. Davidson, 79 Ohio St.3d 116 (1997) (plain-error doctrine should be limited to rare, exceptional cases)
Morales v. Trans World Airlines, Inc., 504 U.S. 374 (1992) (broad construction of phrases like "relating to" and "relate to")