In re D.R.

Citations

• 2021 Ohio 1797

Syllabus

CONSTITUTIONAL LAW – DUE PROCESS – SEX OFFENSES – JUVENILES – R.C. 2152.84: R.C. 2152.84, which provides for a mandatory completion-of-disposition hearing for a juvenile-offender registrant at which the juvenile court must review the effectiveness of the disposition and of any treatment provided the juvenile to determine whether his prior classification as a juvenile-offender registrant should be continued or modified, is unconstitutional as applied to a mandatory juvenile-offender registrant classified at disposition as a Tier I offender, the lowest tier, because the completion-of-disposition hearing is meaningless where the juvenile court could do nothing but continue the juvenile's classification, and therefore, the juvenile was not given an opportunity to be heard at a meaningful time and in a meaningful manner, and because the elimination of the juvenile judge's discretion in determining whether the juvenile had been rehabilitated offended the due-process requirement of fundamental fairness.