State v. Taylor
2017 Ohio 8066
| Ohio Ct. App. | 2017Background
- In 2000, when he was 17, Leon Taylor had sexual intercourse with a 12‑year‑old; the victim identified him and rape‑kit swabs were taken but no arrest followed.
- The families apparently handled the matter privately and the police did not pursue immediate prosecution.
- The rape‑kit DNA was tested 14 years later (2014) and matched Taylor, prompting indictment on rape and kidnapping; Taylor pleaded guilty to sexual battery and received three years’ imprisonment.
- One year after sentencing Taylor moved to vacate his conviction, arguing the common pleas court lacked jurisdiction because he was a juvenile when the offense occurred and the juvenile court therefore had exclusive jurisdiction.
- The sole contested statutory issue was whether Taylor had been “taken into custody or apprehended” for the offense before turning 21, which would divest juvenile court jurisdiction under R.C. 2151.23(I).
- The trial court denied relief; the appellate court affirmed, holding Taylor was not “apprehended” under the statute and that his guilty plea waived preindictment‑delay claims he had declined to pursue.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether juvenile court had exclusive jurisdiction under R.C. 2151.23(I) | State: juvenile court jurisdiction is divested because defendant was not apprehended after 21; common pleas court properly exercised jurisdiction | Taylor: police had identified and were aware of him in 2000, so he was “apprehended” (interpreted as perceived/identified) before 21, so juvenile court had exclusive jurisdiction | Court: “apprehended” means detained/arrested, not merely identified; Taylor was not apprehended before 21; common pleas court had jurisdiction |
| Whether identification/awareness equals being “apprehended” for purposes of the statute | State: statutory language and context imply physical custody/detention, not mere awareness | Taylor: identification and police knowledge in 2000 amounted to apprehension | Held for State: statutory context supports detention meaning; mere awareness insufficient |
| Whether preindictment delay deprived Taylor of due process | Taylor: delay prejudiced him (lost juvenile amenability, different sex‑offender classification, sealing) | State: any prejudice must be proven; burden shifts if prejudice shown | Court: Taylor potentially could show prejudice, but he withdrew earlier motion and pled guilty; guilty plea waived the claim |
| Whether prosecution delay was justified | State: explained testing backlog and investigative circumstances; families discouraged involvement | Taylor: no legitimate explanation for dropping statutory‑rape investigation | Court: Troubled by facts but bound by statute; jurisdictional outcome unaffected despite prosecutorial inaction |
Key Cases Cited
- State v. Luck, 15 Ohio St.3d 150 (Ohio 1984) (preindictment delay that causes actual prejudice can violate due process)
- State v. Whiting, 84 Ohio St.3d 215 (Ohio 1998) (burden shifts to the state to justify delay after defendant shows actual prejudice)
- State v. Jones, 148 Ohio St.3d 167 (Ohio 2016) (actual‑prejudice inquiry is fact‑specific)