In re R.B.

Citations

• 2021 Ohio 2112

Syllabus

JUVENILE – SEX OFFENSES – CLASSIFICATION – COMPLETION-OF-DISPOSITION HEARING – R.C. 2152.83 – R.C. 2152.84: The juvenile's initial R.C. 2152.83 classification by the juvenile court as a Tier I juvenile-offender registrant was valid where the juvenile had previously unsuccessfully challenged his initial classification in an adult criminal case, and where the juvenile court did not lose jurisdiction to classify the juvenile by holding the classification hearing a little over a month after the juvenile's disposition. The juvenile court did not err in failing to hold the R.C. 2152.84 completion-of-disposition hearing when the court released the juvenile from \official probation\ and placed him on nonreporting probation with monitored time, because the juvenile had not yet completed his disposition where the court's order did not expressly end the juvenile's disposition the order left the original disposition, including a suspended commitment to the Department of Youth Services until age 21, in place the order did not impose a new condition of community control where monitored time had always been a part of the juvenile's disposition because the court's dispositional orders had conditioned the suspension of the commitment to the Department of Youth Services on the condition that the juvenile obey all laws and orders of the court and the court's order did not impose any new penalties. The juvenile court had jurisdiction to hold the completion-of-disposition hearing where the hearing was held within a reasonable time of the juvenile's 21st birthday, which marked the end of his disposition. The juvenile court did not violate the juvenile's due-process rights by holding the completion-of-disposition hearing 46 months after the juvenile completed his court-ordered treatment where the court held the completion-of-disposition hearing within a reasonable time of the end of the juvenile's disposition and where the juvenile cannot demonstrate prejudice rising to the level of a due