State v. Young
2020 Ohio 4135
Ohio Ct. App.2020Background
- On April 1, 2019, Wanda Young committed acts leading to charges including two counts of aggravated burglary (first-degree felonies) and other offenses; she pleaded not guilty by reason of insanity (NGRI).
- Psychiatric evaluation found Young suffered bipolar I disorder with psychotic features and a manic episode; the trial court found her NGRI and ordered hospitalization for treatment with the goal of conditional community release.
- At the commitment hearing the trial court concluded Young’s maximum period of court jurisdiction would be 11 years (the pre-Reagan Tokes definite maximum for a first-degree felony) and ruled the Reagan Tokes indefinite ‘tail’ did not apply to NGRI commitments; the state did not object at trial.
- The state appealed, arguing R.C. 2945.401(J)(1)(b) requires using the maximum prison term the defendant could have received, and under the Reagan Tokes Act (applicable to offenses committed after March 22, 2019) that maximum for a first-degree qualifying felony is an indefinite 11 to 16.5 years.
- The appellate court concluded the trial court erred: R.C. 2929.14 and 2929.144 (Reagan Tokes) produce an indefinite maximum term of 11 to 16.5 years for qualifying first-degree felonies, so the court’s jurisdiction over Young’s civil commitment extends up to 16.5 years unless she is released earlier.
- The court reversed and remanded for the trial court to enter commitment judgment authorizing supervision/hospitalization up to 16.5 years (or until Young no longer requires hospitalization); a concurrence and a dissent warned about unresolved constitutional questions and procedural posture.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether R.C. 2945.401(J)(1)(b) requires using Reagan Tokes to calculate the maximum period of court jurisdiction for an NGRI commitment (i.e., 11–16.5 yrs for a first-degree qualifying felony). | State: The statute looks to the maximum prison term the defendant could have received; Reagan Tokes makes that an indefinite 11–16.5 years for qualifying first-degree felonies. | Young/Trial Ct: The applicable maximum is 11 years; the Reagan Tokes indefinite ‘tail’ does not apply to NGRI commitments. | Court: Reagan Tokes applies; maximum civil-commitment supervision for first-degree qualifying felonies is up to 16.5 years. |
| Whether the state’s failure to object below forfeits the issue or may be reviewed (plain error/void-sentence). | State: Although no trial objection, the commitment term is contrary to law and reviewable as plain error or void. | Young: Issue forfeited for failure to raise in trial court; affirm. | Court: Treated the error as plain error in a civil-commitment context and found the statutory language clear; reversal warranted. |
Key Cases Cited
- Goldfuss v. Davidson, 79 Ohio St.3d 116 (establishes very narrow/plain-error standard in civil cases)
- Hill v. Urbana, 79 Ohio St.3d 130 (appellate discretion to consider forfeited issues for plain error)
- In re M.D., 38 Ohio St.3d 149 (discusses appellate consideration of forfeited issues)
- State v. Awan, 22 Ohio St.3d 120 (failure to raise statutory-constitutionality challenge in trial court waives issue)
- State v. Quarterman, 140 Ohio St.3d 464 (courts may decline to consider forfeited constitutional claims on appeal)
- State v. Tuomala, 104 Ohio St.3d 93 (NGRI verdict is not a criminal conviction)