State v. Williams, 2024 Ohio 1433

Timothy Williams, at age 16, killed Leslie Lawson while pretending he was injured and was originally charged in juvenile court with offenses equivalent to murder and felonious assault.
The juvenile court did not consider a tampering with evidence charge but found probable cause on the murder-related charges and transferred (mandatory bindover) Williams to adult court.
In adult court, Williams was indicted by a grand jury for, among other things, a new charge of tampering with evidence based on his disposal of the murder weapon, to which he pleaded guilty along with involuntary manslaughter.
Williams appealed his tampering with evidence conviction, arguing the adult court lacked jurisdiction since that charge was neither brought nor found to have probable cause in juvenile court.
The First District Court of Appeals vacated the conviction, holding that under State v. Smith, the adult court had no subject-matter jurisdiction over the tampering charge.
The State of Ohio appealed, and the Supreme Court reviewed whether charges "rooted in" the same acts for which the juvenile was bound over can be later tried in adult court, reaffirming State v. Burns on this point.

Issue	Williams' Argument	State's Argument	Held
Whether adult court has jurisdiction over new charges not considered in juvenile court but arising from the same acts	Only charges explicitly found to have probable cause by juvenile court can be prosecuted in adult court; Burns was wrongly decided	Charges "rooted in" acts for which juvenile court found probable cause can be prosecuted in adult court; Burns applies	Adult court may try charges "rooted in" acts bound over from juvenile court, even if not individually named earlier
Whether stare decisis requires adherence to Burns	Burns should be overruled as contrary to statutory text and Smith applied strictly	Burns is correct statutory interpretation, and stare decisis applies strongly in statutory cases	Burns reaffirmed; no compelling reason to overrule, especially as legislature could amend statute
Whether the tampering with evidence charge was "rooted in" the conduct found by juvenile court	Tampering with evidence wasn’t included in the complaint, so it’s not "rooted in"	The tampering arose from the same course of events as the killing and was closely linked	The evidence showed it stemmed from the murder conduct—so it is "rooted in"
Whether legislative amendments affect this case	Not specifically argued by Williams	No effect on this pre-2023 case, and amendments support statutory interpretation underpinning Burns	Confirmation that current ruling only applies to pre-amendment cases

State v. Smith, 167 Ohio St.3d 423 (Ohio 2022) (adult court's jurisdiction is limited to acts for which juvenile court found probable cause)
State v. Burns, 170 Ohio St.3d 57 (Ohio 2022) (adult court may try charges not individually named in juvenile court if "rooted in" acts considered and bound over)