In re R.C.

Citations

• 2023 Ohio 4149

Syllabus

SERIOUS YOUTHFUL OFFENDER ¬– R.C. 2152.14 – DOCTRINE OF LACHES – DUE PROCESS – INEFFECTIVE ASSISTANCE OF COUNSEL – DISCOVERY ¬– EVIDENCE – EXCLUSIONARY RULE ¬– AUTHENTICATION: The juvenile court did not err when it rejected the juvenile defendant's doctrine-of-laches argument where the government's delay in bringing its motion to invoke the suspended adult portion of defendant's Serious Youthful Offender (\SYO\) disposition was based on a reasonable justification. The juvenile court did not err to the prejudice of defendant's due-process or effective-assistance-of-counsel rights when it rejected several of defendant's evidentiary objections because evidence was turned over to defendant's adult-court counsel, neither the Ohio Rules of Evidence nor the exclusionary rule applies to SYO-invocation proceedings, and court records were properly admitted. The juvenile court did not err when it invoked the adult portion of defendant's SYO disposition because the court's decision was supported by sufficient evidence and was not against the manifest weight of the evidence where there was clear and convincing evidence that defendant was in possession of a fentanyl-related compound and was in constructive possession of two firearms while under disability.