State v. Reynolds
2020 Ohio 4354
Ohio Ct. App.2020Background
- Jessica Reynolds was charged in county court with first‑degree misdemeanor domestic violence and child endangering. She pleaded not guilty and executed a written jury‑waiver form.
- The waiver form was filed and made part of the record before trial, and Reynolds’ case proceeded as a bench trial.
- The trial court acknowledged receipt of the written waiver at the first day of trial but did not personally ask Reynolds, in open court and in the presence of counsel, to orally acknowledge her waiver.
- The court convicted Reynolds of both offenses and sentenced her; the state later conceded the trial court lacked jurisdiction over the child endangering charge.
- The appellate court vacated the child‑endangering conviction for lack of jurisdiction and held the jury waiver invalid for failure to satisfy the R.C. 2945.05 “in open court” requirement, reversed the domestic‑violence conviction, and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether Reynolds validly waived jury trial under R.C. 2945.05’s “in open court” requirement | The court’s on‑the‑record acknowledgment of receipt of a written, filed waiver was sufficient to proceed without further colloquy | Reynolds did not orally acknowledge the waiver in open court in the presence of counsel, so the waiver was not made "in open court" | Waiver invalid: written, signed, and filed waiver alone insufficient; no oral in‑court acknowledgment — bench trial lacked jurisdiction; conviction reversed and remanded |
| Whether the municipal/county court had jurisdiction over the child endangering charge | The State ultimately conceded lack of jurisdiction | Reynolds argued juvenile court has exclusive original jurisdiction over adult prosecutions under R.C. 2151.23 for child endangering under R.C. 2919.22(B)(1) | Conviction vacated for lack of jurisdiction; exclusive jurisdiction lies with juvenile court absent applicable felony‑indictment exception |
Key Cases Cited
- State v. Lomax, 114 Ohio St.3d 350 (2007) (a written, signed, filed waiver must be accompanied by some in‑court acknowledgment by the defendant in the presence of counsel to satisfy R.C. 2945.05)
- State v. Pless, 74 Ohio St.3d 333 (1996) (absent strict compliance with jury‑waiver requirements, a trial court lacks jurisdiction to try the defendant without a jury)