State v. Brown

Citations

• 2021 Ohio 3348

Syllabus

R.C. 2907.21(A)(3)(a) compelling prostitution constitutionality void for vagueness R.C. 2967.191(A) jail-time credit GPS home monitoring. R.C. 2907.21(A)(3)(a), compelling prostitution, is not unconstitutionally vague for not defining the term \minor\ and for criminalizing an offender's conduct even if the offender thinks the victim is a minor, but the victim is actually an adult. R.C. 2907.01(M), which applies to R.C. 2907.21, defines \minor\ as \a person under the age of eighteen.\ If an offender were to knowingly pay or agree to pay someone for sex, and that person were not a minor, the elements for compelling prostitution under R.C. 2907.21(A)(3)(a) would not be met. The defendant was also not entitled to jail-time credit for the days he spent subject to GPS home monitoring. Confinement in a personal residence is not confinement within the meaning of R.C. 2967.191(A).