State v. Stanford, 2018 Ohio 3961

Keith D. Stanford (age 16) faced juvenile complaints alleging three aggravated robberies (with firearm specification), one burglary, and one robbery; the State moved for bindover to adult court (mandatory for the firearm specification; discretionary for other counts).
At a juvenile probable-cause hearing, Stanford stipulated to probable cause and (for two discretionary-transfer matters) that he was not amenable to juvenile rehabilitation; the parties agreed on a joint recommended 10-year adult sentence.
The juvenile court relinquished jurisdiction and bound the cases over to Franklin County Common Pleas; an indictment followed, Stanford pled guilty to multiple counts and a single three-year firearm specification, and the trial court imposed the agreed 10-year term.
On appeal Stanford raised four assignments of error: (1) waiver of amenability hearing was not knowing/voluntary, (2) failure to appoint a guardian ad litem under Juv.R.4(B)(2)/R.C.2151.281(A)(2), (3) mandatory bindover statutes are unconstitutional, and (4) ineffective assistance of counsel for not litigating the prior points.
The appellate court reviewed waived issues for plain error where applicable, examined the hearing transcript and totality of circumstances, and evaluated counsel performance under Strickland.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1. Whether the juvenile court accepted a knowing, intelligent, voluntary waiver of an amenability hearing	State: colloquy and counsel's involvement show a valid waiver/stipulation	Stanford: court failed to engage in a meaningful colloquy and explain amenability, statutory procedures, and consequences	Court: Waiver/stipulation was knowing, intelligent, voluntary under D.W.; no plain error — overruled
2. Whether a guardian ad litem should have been appointed under Juv.R.4(B)(2)/R.C.2151.281(A)(2)	State: no conflict of interest existed between Stanford and his parents; parents sought best outcome	Stanford: parents' statements and objections showed a conflict requiring GAL appointment	Court: No plain error; parents' interests aligned with juvenile's and no sufficient potential conflict — overruled
3. Constitutional challenge to mandatory bindover statutes (due process/equal protection)	State: statutes are constitutional	Stanford: mandatory transfer provisions violate due process and equal protection	Court: Followed Ohio Supreme Court in Aalim — statutes constitutional; claim rejected
4. Ineffective assistance for failing to object to transfer/waiver/GAL issues	State: counsel's omissions were reasonable; underlying claims lack merit	Stanford: counsel should have litigated the above errors	Court: No deficient performance or prejudice under Strickland; claims fail

State v. D.W., 133 Ohio St.3d 434 (Ohio 2012) (juvenile amenability-hearing waiver requires express on-the-record waiver and a colloquy to ensure it is knowing, voluntary, and intelligent)
In re C.S., 115 Ohio St.3d 267 (Ohio 2007) (judges must engage in a meaningful, inquisitorial dialogue before accepting juvenile waivers of rights)
State v. Aalim, 150 Ohio St.3d 489 (Ohio 2017) (mandatory juvenile bindover statutes comply with due process and equal protection)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-pronged ineffective-assistance standard: deficient performance and prejudice)
State v. Barnes, 94 Ohio St.3d 21 (Ohio 2002) (plain-error framework under Crim.R. 52(B))
State v. Holloway, 38 Ohio St.3d 239 (Ohio 1988) (failure to object is not alone sufficient to prove ineffective assistance)