State v. Reeder, 57 N.E.3d 458

In Feb. 2013, 14-year-old Joseph Q. Reeder shot and killed 64-year-old Anthony Hines in Reeder's home; police charged Reeder with murder, aggravated robbery, and tampering with evidence.
Reeder surrendered, gave a videotaped statement admitting he shot Hines, took Hines' car and wallet contents, and discarded the gun; some forensic evidence (DNA in pockets, close-range gunshot wounds) was introduced.
A four-day juvenile amenability/transfer hearing was held after preliminary probable cause findings; Reeder had prior juvenile adjudications and had cut off an ankle monitor prior to the incident.
A defense expert opined Reeder was amenable to rehabilitation in juvenile facilities (50–55% chance by age 21), but the juvenile court questioned the report's strength and completeness.
The juvenile court found and balanced statutory transfer factors under R.C. 2152.12, concluded Reeder was not amenable to juvenile rehabilitation and that community safety required adult sanctions, and bound him over to adult court; Reeder later pled under Alford and was sentenced to 17 years.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile court sufficiently articulated reasons and considered statutory factors before binding over Reeder	State: juvenile court considered and weighed R.C. 2152.12 factors and record supports transfer	Reeder: court abused discretion and failed to articulate adequate reasoning that juvenile rehabilitation was unavailable	Court: No abuse of discretion; record (oral and written findings) shows specific R.C. 2152.12 factors were considered and balanced
Whether transfer/relinquishment to adult court was erroneous on the facts	State: factors (death of victim, victim vulnerability, firearm use, prior noncompliance with juvenile sanctions) outweigh factors against transfer	Reeder: factors favoring juvenile disposition (expert amenability opinion, provocation/self-defense claims, youth) outweigh transfer	Court: Transfer justified—seriousness of crime, firearm, victim vulnerability, prior juvenile history and safety concerns supported bindover

Kent v. United States, 383 U.S. 541 (requirement that juvenile transfer proceedings show consideration of specific factors)
North Carolina v. Alford, 400 U.S. 25 (legal framework for an Alford plea)
Hall v. Florida, 134 S. Ct. 1986 (terminology and treatment of intellectual disability)
In re A.J.S., 120 Ohio St.3d 185 (2008) (juvenile transfer review; courts cannot commit errors of law)
State v. D.W., 133 Ohio St.3d 434 (2012) (juvenile-bindover standards and need to show consideration of statutory factors)
State v. Watson, 47 Ohio St.3d 93 (Ohio Supreme Court recognition that seriousness of the crime may be considered in transfer decisions)