State v. Peterson, 2024 Ohio 5379

Jacob A. Peterson was indicted by a Licking County Grand Jury on two counts of rape and two counts of gross sexual imposition involving a victim under the age of thirteen.
Peterson initially pleaded not guilty but later changed his plea to guilty on one count of rape and one count of gross sexual imposition; the remaining counts were dismissed.
The trial court thoroughly explained Peterson's rights under Crim.R. 11 prior to accepting his plea, and Peterson acknowledged his understanding and guilt.
Peterson received an agreed sentence of fifteen years to life for rape and five years for gross sexual imposition, to be served consecutively (totaling twenty years to life).
Peterson was declared a Tier III sexual offender and sentenced to post-release control.
Peterson's appellate counsel filed an Anders brief, asserting that the appeal was wholly frivolous but raising a potential argument based on subject-matter jurisdiction and the timing of the offenses relative to Peterson's age.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether trial court had subject-matter jurisdiction to convict and sentence Peterson, given possible juvenile jurisdiction based on indictment dates	State did not file a brief or argument	Peterson (via counsel) argued that the indictment alleged offenses occurring potentially before Peterson turned 18, thus should have involved juvenile bindover procedure	The court held there was no merit because Peterson admitted to being 18 at the time of the offenses, never raised the argument below, and entered a valid guilty plea
Whether Peterson’s guilty plea was properly accepted under Crim.R. 11	N/A	No specific challenge; potential argument that plea was invalid if jurisdiction was lacking	The court found the plea was voluntary, knowing, and complied with procedural rules
Whether Peterson’s sentence was authorized and reviewable on appeal given the agreed sentence	State did not contest	No specific challenge on sentencing beyond jurisdictional issue	The sentence was within statutory limits and not reviewable under Ohio law for jointly recommended sentences
Whether any non-frivolous issue existed for appeal under Anders	N/A	Only raised the above jurisdictional concern	The court determined appeal to be wholly frivolous, counsel permitted to withdraw, appeal dismissed

Anders v. California, 386 U.S. 738 (1967) (establishes procedure for withdrawal by counsel on appeal if the appeal is frivolous)
State v. Childs, 14 Ohio St.2d 56 (1968) (appellate courts will not consider errors not raised at trial that could have been corrected)