In re J.C.

Citations

• 2022 Ohio 850

Syllabus

JUVENILE – EVIDENCE – RELEVANCE – AUTHENTICATION – DURESS – R.C. 2923.12 – COMPLAINT – MENS REA – JUV.R. 29(F)(2)(d): The state adequately authenticated a handgun where witnesses testified that the evidence was what the state purported it to be, despite the fact that those witnesses did not testify as to chain of custody. The juvenile court did not commit reversible error by excluding the criminal record of a third-party who allegedly placed the juvenile under duress because the probative value of the criminal record was negligible and the juvenile could not prove all of the elements of duress even if that evidence was admitted. The state presented sufficient evidence to establish that the juvenile possessed a deadly weapon under R.C. 2923.12(A) where it put on undisputed evidence that she possessed a handgun, which is a deadly weapon under R.C. 2923.11. The complaint was not deficient for failing to charge the juvenile under the relevant subsection of R.C. 2923.12 where the complaint unambiguously described the nature and scope of the prohibited conduct. The juvenile court's finding that the juvenile concealed a handgun was not against the weight of the evidence where the juvenile and the state's witnesses gave conflicting testimony and the juvenile court made a credibility determination in the state's favor.