In re T.B.

Citations

• 2026 Ohio 1309

Syllabus

FOURTH AMENDMENT — OHIO CONST., ART. I, § 14 — TERRY — REASONABLE SUSPICION — JAYWALKING — R.C. 2935.26(A) — AUTOMATIC-COMPANION RULE — EVID.R. 901(A) — AUTHENTICATION — CHAIN OF CUSTODY — SUFFICIENCY — MANIFEST WEIGHT — CARRYING CONCEALED WEAPONS — MOTION TO WITHDRAW A PLEA: The juvenile court did not err in denying juvenile's motion to suppress the gun found on his person as the fruit of an unreasonable seizure because an officer had observed the juvenile crossing the street illegally and was therefore authorized to perform a limited detention for the purpose of citing juvenile, as contemplated by R.C. 2935.26(A). The juvenile court did not err in denying juvenile's motion to suppress the gun found on his person as the fruit of an unreasonable search because the officer who stopped juvenile reasonably suspected that juvenile was armed and dangerous based on (1) another officer's report that juvenile and his companion had bulges consistent with firearms in their waistband areas, and (2) the officer's own frisk of the companion, which revealed a firearm, thereby corroborating the other officer's report. The juvenile court did not err in denying juvenile's motion to exclude the firearm found on his person under Evid.R. 901(A) where body-worn-camera footage and officer testimony provided a rough chain of custody stretching back to the moment the gun was removed from juvenile's person. Sufficient evidence supported the juvenile court's finding that the firearm taken from juvenile's person was operable, and that finding was not against the manifest weight of the evidence. The juvenile court abused its discretion by implicitly denying juvenile's motion to withdraw his plea of \admit\ to the jaywalking charge, where (1) juvenile was presumptively entitled to withdraw his plea because he had made his motion prior to any final order of disposition, (2) the juvenile court had granted juvenile's contemporaneous motion to withdraw his plea to the concealed-carry charge, and (3