In re L.M.

Citations

• 2024 Ohio 2974

Syllabus

JUVENILE – COMPETENCY – SUFFICIENCY – RECEIVING STOLEN PROPERTY – POSSESSING CRIMINAL TOOLS: Because defendant's attorney informed the juvenile court that defendant had demonstrated a marked decline in his ability to process and retain information following a car crash, which caused a traumatic brain injury, the juvenile court erred when it denied defendant's motion for a competency evaluation because the attorney's representations of defendant's change in condition and a medical cause for the change constitute a reasonable basis to order a competency evaluation. Defendant's adjudication of delinquency for receiving stolen property was based on sufficient evidence where defendant was found alone in a recently-wrecked car, there were no keys in the car, the steering column had been peeled, and defendant was in possession of tools particularly suited to the theft of the specific type of car. Defendant's adjudication of delinquency for possession of criminal tools was based on sufficient evidence where the evidence supported an inference that the car possessed by defendant had recently been stolen, and defendant was in possession of tools particularly suited to the theft of the specific type of car.