In re E.K.

Citations

• 2024 Ohio 5291

Syllabus

JUVENILE COURT — SUBJECT-MATTER JURISDICTION — R.C. 2152.02 — PAROLE VIOLATION — JUV.R. 9 — MOOT: Where a person is adjudicated a delinquent child prior to attaining 18 years of age, the juvenile court has jurisdiction over the person for matters related to the adjudication until the person attains 21 years of age. The juvenile court erred in dismissing a complaint for a parole violation on the ground that the court lacked subject-matter jurisdiction over the person that was the subject of the complaint where the person had not yet attained 21 years of age. The juvenile court's dismissal of a complaint for a parole violation could not be upheld pursuant to Juv.R. 9(A) where the juvenile court plainly dismissed the complaint based on a mistaken belief that it lacked subject-matter jurisdiction and where the dismissal was not based on a need to protect either the accused or the community or because the court believed that continuing with a prosecution of the parole violation was not in the accused's best interest. An appeal from the juvenile court's dismissal of a complaint on jurisdictional grounds was not moot where a live controversy remained following a reversal of the jurisdictional determination and where the juvenile court could grant meaningful relief.