State v. Watkins
2018 Ohio 46
| Ohio Ct. App. | 2018Background
- In May 2016, 16‑year‑old Michael Watkins orchestrated a robbery in which two minors lured victims to an apartment; victims were threatened with a gun, assaulted, and robbed. Watkins was arrested the same day.
- While detained on the juvenile charges, Watkins allegedly assaulted a corrections officer; the state filed a felonious‑assault charge as well.
- The state sought mandatory bindover on the aggravated‑robbery counts (gun specification) and discretionary bindover on other charges. The juvenile court found probable cause but denied mandatory bindover (no finding Watkins personally possessed or displayed the firearm) and later granted discretionary bindover after an amenability hearing.
- Watkins was indicted in common pleas court, pleaded no contest to two aggravated robberies (without gun specs) and felonious assault, then sought to withdraw pleas to challenge the juvenile bindover; the trial court denied withdrawal and sentenced him to an aggregate eight‑year term.
- On appeal Watkins raised (inter alia) challenges to the juvenile court’s discretionary‑bindover findings and process (including sufficiency of mental‑exam waiver and notice), an alleged due‑process taint from budgetary motives, the trial court’s denial of plea withdrawal, and whether his youth was considered at sentencing.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Watkins) | Held |
|---|---|---|---|
| 1. Whether juvenile court abused its discretion granting discretionary bindover under R.C. 2152.12(B) | Juvenile court properly weighed statutory factors and found juvenile not amenable; record supports findings | Juvenile court misweighed/relied on findings unsupported by record; factors (8) maturity and (9) insufficient time to rehabilitate are unsupported | Affirmed: no abuse of discretion; court considered required factors and record provides rational basis for findings |
| 2. Whether juvenile court’s process violated due process because decision was motivated by financial considerations | No evidence financial motives affected the decision; mere absence of DYS commitments in county does not prove bias | Bindover was tainted by court’s funding concerns (county avoided DYS commitments) | Affirmed: no evidence that financial considerations influenced the court; due‑process claim fails |
| 3. Whether juvenile court complied with R.C. 2152.12(C) and (G) re: mental exam and notice | One recent mental exam (and prior evaluation) was available and counsel agreed to its use; notice was given by entry and key participants attended | Juvenile court failed to obtain a competent waiver from Watkins for the second exam and failed to give statutorily required written notice to custodians | Affirmed: use of the June 30 exam was not prejudicial; notice by entry and attendance of counsel/guardians was sufficient under circumstances |
| 4. Whether trial court erred by denying motion to withdraw no‑contest pleas to consider constitutional bindover challenges | Trial court lacked jurisdiction to review juvenile court bindover; common pleas court cannot decide bindover validity | Watkins sought to withdraw pleas so the trial court could address constitutional defects in the bindover | Affirmed: trial court correctly denied withdrawal because it lacked jurisdiction to review juvenile bindover order |
| 5. Whether sentencing violated Eighth Amendment/Ohio law for failing to consider youth | Trial court expressly considered age and sentenced within statutory range, making required findings for consecutive terms | Trial court failed to give adequate weight to Watkins’ youth and thus imposed cruel/unusual punishment | Affirmed: record shows trial court considered age; sentence was within statutory limits and not contrary to law |
Key Cases Cited
- State v. D.W., 133 Ohio St.3d 434 (2012) (distinguishes mandatory and discretionary bindover procedures)
- State v. Marcum, 146 Ohio St.3d 516 (2016) (standard of appellate review for felony sentences under R.C. 2953.08)
- State v. Watson, 47 Ohio St.3d 93 (1989) (greater culpability reduces amenability to rehabilitation)
- In re Becker, 39 Ohio St.2d 84 (1974) (appellate timing and limits for challenges to juvenile bindover)