State v. Young, 125 N.E.3d 177

Christopher Young was indicted for failing to notify the sheriff of a change of address under R.C. 2950.05(F)(1) and pled guilty; the trial court sentenced him to seven months in prison.
Young did not raise a constitutional objection in the trial court; he claimed on appeal the plea acceptance was plain error.
Young's argument: a juvenile adjudication cannot serve as the predicate for an adult conviction under the failure-to-notify statute, and using it violates due process per State v. Hand.
The trial court conviction rested on a duty-to-notify that arose from a juvenile adjudication (R.C. 2950.05(B)), although the failure-to-notify provision itself does not call a juvenile adjudication a conviction.
The court reviewed the claim under plain-error standards (Crim.R. 52(B)) and considered Hand and more recent Ohio Supreme Court guidance distinguishing sentence-enhancement uses of juvenile adjudications from statutes that make adjudications an element of an offense.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Young)	Held
Whether acceptance of Young’s guilty plea to failing to notify was plain error because a prior juvenile adjudication cannot be the predicate for the offense and its use violates due process	The statute and precedent (Carnes, Buttery) permit treating a juvenile adjudication as the predicate element of the statutory duty-to-notify; no due-process violation when the adjudication is an element, not a sentence enhancer	Hand prohibits treating juvenile adjudications as equivalent to adult convictions for sentence enhancement; thus using a juvenile adjudication to support an adult criminal conviction (failure-to-notify) violates due process	The court held there was no plain error: using the juvenile adjudication as the basis for the duty-to-notify did not obviously violate due process under current law; conviction affirmed

State v. Hand, 149 Ohio St.3d 94 (Ohio 2016) (juvenile adjudications cannot be treated as adult convictions for sentence-enhancement purposes)
Apprendi v. New Jersey, 530 U.S. 466 (U.S. 2000) (any fact other than prior conviction that increases penalty beyond statutory maximum must be submitted to a jury)
Alleyne v. United States, 570 U.S. 99 (U.S. 2013) (facts increasing mandatory minimum must be found by a jury)
In re D.S., 146 Ohio St.3d 182 (Ohio 2016) (imposing juvenile registrant/notification duties that extend into adulthood does not violate due process)
State v. Blankenship, 145 Ohio St.3d 221 (Ohio 2015) (legislative purpose of sex-offender registration statutes is public protection)