In re J.D.

Citations

• 2025 Ohio 746

Syllabus

Juvenile court; competency hearing; R.C. 2152.51 through 2152.59; ineffective assistance of counsel; statutory timing requirements for conducting competency evaluations of juveniles; failure to order residential competency treatment. Juvenile court's judgment adjudicating the juvenile delinquent and committing him to the Ohio Department of Youth Services is reversed. Evidence in the record showed that the juvenile was likely incompetent when he entered his admission to aggravated robbery. Additionally, the court erred when it failed to comply with various timing requirements in the juvenile competency statutes. The juvenile's counsel was ineffective for failing to raise the issue of competency, failing to file a motion to withdraw the admission, and failing to object to the court not complying with the statutory timing requirements concerning competency. Furthermore, the court erred when it found that it had no \authority\ to refer the juvenile for residential competency treatment.