State v. Washington, 2014 Ohio 4178

On Oct. 14–16, 2011, then-15-year-old Brendan Washington participated with three others in shootings that killed Rudell Englemon and, two days later, Carrielle Conn (to prevent her from informing). Washington admitted involvement during a recorded police interrogation.
Washington was apprehended, interrogated (DVD-recorded), and charged via a juvenile delinquency complaint; detectives preserved a waiver-of-rights form and a DVD of the interrogation.
The juvenile court conducted a discretionary-transfer proceeding, reviewed a psychological amenability evaluation by Dr. Kathleen Hart, and ordered transfer to common pleas court on Nov. 30, 2011.
A grand jury indicted Washington on multiple counts, including two aggravated murders; the trial court denied his motion to suppress his statements.
Washington entered no-contest pleas to all charges; the trial court convicted him and imposed an aggregate sentence of 25 years to life.
Washington appealed, arguing (1) erroneous juvenile-court transfer, (2) involuntary/confessed statements should have been suppressed, and (3) ineffective assistance of counsel. The appellate court affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Washington)	Held
Validity of discretionary transfer from juvenile to adult court	Juvenile court properly found probable cause and that statutory transfer factors favored adult disposition	Transfer was erroneous: insufficient probable cause tying Washington to murders and juvenile factors (rehabilitation prospects) were not properly weighed	Affirmed: probable cause supported; juvenile court considered applicable statutory factors and did not abuse discretion in amenability finding
Admissibility of statements (Miranda waiver)	Recorded interrogation and signed waiver presumptively show voluntary, knowing waiver; prosecution met burden under R.C. 2933.81	Waiver involuntary due to youth, fatigue, lack of counsel/family, and alleged police trickery/coercion	Affirmed: totality of circumstances showed voluntary, knowing waiver; DVD recording and signed form strongly support admissibility
Ineffective assistance of counsel at amenability hearing	Counsel reasonably challenged transfer using Dr. Hart’s report and argued mitigating factors; strategy and witness decisions are within tactical judgment	Counsel was ineffective for not obtaining independent psychological expert and not calling family/friends to attest to immaturity	Affirmed: Washington failed to show deficient performance or prejudice under Strickland; counsel’s arguments were adequate and within trial strategy

In re M.P., 923 N.E.2d 584 (Ohio 2010) (juvenile exclusive jurisdiction and standards for transfer/amenability review)
In re A.J.S., 897 N.E.2d 629 (Ohio 2008) (two-component discretionary-transfer framework: probable cause then amenability)
State v. D.W., 978 N.E.2d 894 (Ohio 2012) (distinguishing mandatory and discretionary juvenile transfers)
State v. Morris, 972 N.E.2d 528 (Ohio 2012) (review of amenability determinations and abuse-of-discretion standard)
Miranda v. Arizona, 384 U.S. 436 (U.S. 1966) (Miranda waiver standards)
Strickland v. Washington, 466 U.S. 668 (U.S. 1984) (two-part ineffective-assistance test)