State v. Thomas, 2017 Ohio 7520

Trenex Thomas was indicted in Ohio for failing to verify his residence (R.C. 2950.06) and failing to notify the sheriff of an address change (R.C. 2950.05) in March 2016; both third-degree felonies.
Thomas had been adjudicated a delinquent juvenile in Cooke County, Illinois, in 2000 for aggravated criminal sexual assault and was ordered to register as a sex offender; he first registered in Ohio in 2010.
Thomas moved to dismiss, arguing Illinois law imposed only a 10-year registration duty that expired in 2010, so he had no continuing Ohio registration obligation.
The trial court denied the motion, relying on the Illinois Supreme Court’s decision in In re J.W., which treated a juvenile adjudication for aggravated criminal sexual assault as a sexual-predator classification carrying a lifetime registration duty.
Thomas pleaded no contest to failure to verify in exchange for dismissal of the other count; the court accepted the plea and initially imposed community control (later revoked and converted to prison time).
Appellate counsel filed an Anders brief concluding no arguable issues; the appellate court conducted an independent Anders review and affirmed the conviction as frivolous on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Illinois juvenile adjudication imposed only a 10‑year registration duty, relieving Thomas of Ohio registration duties	Illinois law (per State) requires lifetime registration for juveniles adjudicated of aggravated criminal sexual assault (In re J.W. controls)	Thomas argued Illinois imposed only a 10‑year duty that expired in 2010, so Ohio registration obligations no longer applied	Court held Illinois law, as interpreted in In re J.W., imposed a lifetime duty; trial court correctly denied dismissal
Whether there are any meritorious appellate issues after plea and sentencing	State contended proceedings and plea colloquy complied with law; no reversible error shown	Thomas (via counsel) asserted no nonfrivolous issues to raise on appeal	Court found no issues of arguable merit under Anders and affirmed judgment

Anders v. California, 386 U.S. 738 (1967) (requires counsel who finds appeal frivolous to file brief and court to conduct independent review)
In re J.W., 204 Ill.2d 50 (2003) (Illinois Supreme Court: juvenile adjudication for aggravated criminal sexual assault constitutes sexual‑predator classification and requires lifetime registration)