State v. Williams, 2022 Ohio 2022

Defendant Timothy Williams was 16 when arrested on conduct that would have been murder and felonious assault if committed by an adult.
Juvenile court held a mandatory bindover hearing, found probable cause for two murder counts and one felonious-assault count (with firearm specifications), and relinquished jurisdiction as to those charges.
In adult common pleas court the state indicted Williams for two murder counts (with firearm specs), one felonious-assault count (with a firearm spec), and a separate count of tampering with evidence (R.C. 2921.12(A)(1)).
Williams pleaded guilty (per a plea agreement) to a reduced involuntary-manslaughter count and to tampering with evidence; the court imposed a three-year consecutive sentence on the tampering count.
On appeal Williams argued the trial court lacked subject-matter jurisdiction over the tampering count because the juvenile court never found probable cause as to that act; the State conceded the point at oral argument.
The appellate court vacated the tampering conviction and remanded, holding the adult court lacked jurisdiction over the tampering count absent a juvenile-court probable-cause finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the adult court had subject-matter jurisdiction to convict Williams of tampering with evidence when the juvenile court never found probable cause for that act	State conceded at oral argument that, under controlling precedent, the adult court lacked jurisdiction because the juvenile court made no probable-cause finding for tampering	Williams: juvenile court never transferred jurisdiction for the tampering act; absent an R.C. 2152.12 probable-cause finding, adult prosecution is barred	Court vacated the tampering conviction: adult court lacked subject-matter jurisdiction because juvenile court never found probable cause for that act
Whether Williams received ineffective assistance of counsel for failing to object to the tampering count	State: not materially argued given concession	Williams: counsel ineffective for not objecting to indictment/conviction on tampering	Declared moot by the court because jurisdictional error disposed of the case

In re M.P., 923 N.E.2d 584 (Ohio 2010) (juvenile courts have exclusive jurisdiction over delinquency matters)
Steele v. Harris, 163 N.E.3d 565 (Ohio 2020) (describing the bindover procedure and transfer of jurisdiction)
State v. Wilson, 652 N.E.2d 196 (Ohio 1995) (bindover procedure principles; juvenile court jurisdiction rule)
State v. Payne, 873 N.E.2d 306 (Ohio 2007) (void judgments result from lack of subject-matter jurisdiction)