2021 Ohio 3071
Ohio Ct. App.2021Background
- In Feb. 2019, then-16-year-old Clayton Ramsden (unlicensed) drove erratically and caused a multi-vehicle crash that killed his girlfriend, Wendy Brewer, and her infant daughter, A.D.; others suffered serious injuries and Ramsden was hospitalized.
- About four weeks later (Mar. 11, 2019) Ramsden was stopped for driving without headlights; officers found 24 individually wrapped marijuana edibles (over 200 grams) in the vehicle and a passenger said they were for sale.
- Two juvenile complaints were filed (ten alleged felonies total). The state moved for discretionary bindover under R.C. 2152.12(B) to prosecute Ramsden as an adult.
- After an amenability hearing (testimony from school officials, children services worker, and coroner), the juvenile court found probable cause, concluded Ramsden was not amenable to juvenile rehabilitation, and bound the cases over to common pleas court.
- Ramsden was indicted, pled guilty to two counts of aggravated vehicular homicide and one count of assault, and was sentenced to an aggregate five-year prison term. He appealed the bindover, claiming the juvenile court abused its discretion.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the juvenile court abused its discretion in binding Ramsden over under R.C. 2152.12(B)(3) (amenability/public safety) | Ramsden: the juvenile court's finding that he was not amenable was speculative, baseless, and contrary to the evidence | State: juvenile court considered statutory factors, evidence (fatal crash, rapid reoffense, substance abuse, school misconduct, maturity) supported bindover | Court: affirmed — no abuse of discretion; record provides rational basis to support bindover |
Key Cases Cited
- State v. Golphin, 81 Ohio St.3d 543 (Ohio 1998) (juvenile court has exclusive initial subject-matter jurisdiction over felony delinquency matters)
- State v. Wilson, 73 Ohio St.3d 40 (Ohio 1995) (explaining discretionary bindover under R.C. 2152.12(B))
- State v. Watson, 47 Ohio St.3d 93 (Ohio 1989) (greater culpability of the offense diminishes amenability to juvenile rehabilitation)
- State v. Hanning, 89 Ohio St.3d 86 (Ohio 2000) (juvenile court has discretion to transfer juveniles who are not amenable to juvenile rehabilitation)
- Johnson v. Sloan, 154 Ohio St.3d 476 (Ohio 2018) (recognizing juvenile-court discretion to transfer or bind over certain juveniles)
- State v. May, 159 Ohio St.3d 106 (Ohio 2020) (describing discretionary bindover procedure under R.C. 2152.12)