State v. Strickland, 2023 Ohio 1252

In April 2005 a juvenile complaint charged then-17-year-old Tommie Strickland with aggravated murder and aggravated robbery (same victim, same date) arising from a March 12, 2005 mall shooting.
Juvenile court held a probable-cause hearing, found probable cause for aggravated murder and aggravated robbery (and related firearm allegations), and transferred the matter to adult court.
A grand jury later indicted Strickland on five counts (aggravated murder, aggravated robbery, two robbery counts, and kidnapping) with firearm specifications; the additional robbery and kidnapping counts alleged the same date and victim.
After trial the jury convicted Strickland on all counts and firearm specifications; he was sentenced to 40 years. Appeals and federal habeas relief were unsuccessful.
In 2022 Strickland filed a pro se motion to vacate his convictions relying on State v. Smith, arguing the adult court lacked subject-matter jurisdiction to convict him of counts for which the juvenile court had not made a probable-cause finding. The trial court denied the motion and the Tenth District affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the adult court lacked subject-matter jurisdiction to try/convict Strickland for counts not specifically found supported by probable cause in juvenile court	State: Smith applies only where juvenile court expressly found no probable cause; here juvenile court found probable cause for the transferred offenses and R.C. 2151.23(H) permits convictions "rooted in" the transferred acts	Strickland: Under Smith, convictions for offenses not supported by juvenile-court probable cause (the two robbery counts and kidnapping) are void for lack of jurisdiction	Affirmed: Court distinguished Smith and held Burns controls — adult court may hear charges "rooted in" conduct in the juvenile complaint; convictions not void for lack of jurisdiction
Whether the trial court erred in denying Strickland’s motion to vacate his convictions as void	State: The convictions were valid because either (1) juvenile court found probable cause for the transferred offenses, or (2) R.C. 2151.23(H) allows conviction of offenses rooted in the transfer	Strickland: Motion to vacate should be granted because the bindover did not confer jurisdiction over offenses for which juvenile court made no probable-cause finding	Affirmed: Motion properly denied; no Smith-type jurisdictional defect existed here

State v. Smith, 167 Ohio St.3d 423 (Ohio 2022) (adult court lacks subject-matter jurisdiction over acts for which juvenile court found no probable cause)
State v. Adams, 69 Ohio St.2d 120 (Ohio 1982) (grand jury may return an indictment on any charges supported by the facts submitted)