State v. Wilson, 2017 Ohio 7223

Defendant Dacoldest Wilson (15 at the time) was charged in juvenile court with felonious assault and aggravated robbery (with a gang specification) after attempting to drive off in a victim's car, throwing her to the ground.
The State moved to transfer the case to adult court under R.C. 2152.12(B); Wilson waived a probable-cause hearing and a psychological evaluation/investigation was ordered and completed.
At the amenability hearing the parties stipulated to the psychological report; the juvenile court found Wilson not amenable to juvenile rehabilitation and certified him to the Montgomery County Common Pleas Court, General Division.
In adult court Wilson pled guilty to aggravated robbery in exchange for dismissal of the other count and the gang specification; at sentencing the trial court imposed a three-year mandatory prison term based on a prior juvenile adjudication that would have been a felony if committed by an adult.
The appellate court affirmed the transfer (no abuse of discretion) but held the mandatory sentence was imposed in error under binding Ohio Supreme Court precedent and remanded for resentencing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether juvenile court abused its discretion by transferring Wilson to adult court	The State argued transfer appropriate: Wilson was ≥14, probable cause existed, prior juvenile sanctions failed, community safety required adult sanctions	Wilson argued he was amenable to juvenile rehabilitation and transfer was unnecessary	Court held juvenile court did not abuse its discretion; transfer supported by record (prior sanctions, treatment failures, maturity, community safety)
Whether a prior juvenile adjudication can trigger a mandatory adult prison term	State (initially) relied on prior juvenile adjudication as equivalent to an adult prior for sentencing enhancement under R.C. 2929.13(F)(6)	Wilson argued using a juvenile adjudication to convert a non-mandatory sentence into a mandatory term violates due process	Court held (conceding State) that under Ohio Supreme Court precedent a juvenile adjudication cannot be treated as an adult conviction to enhance sentence; mandatory term was erroneous and resentencing is required

In re M.P., 923 N.E.2d 584 (Ohio 2010) (amenability-transfer standard and abuse-of-discretion review)
Blakemore v. Blakemore, 450 N.E.2d 1140 (Ohio 1983) (abuse-of-discretion definition)
State v. Hand, 73 N.E.3d 448 (Ohio 2016) (holding juvenile adjudication cannot be used as equivalent of adult conviction to enhance sentence)