State v. D.T.

Citations

• 2024 Ohio 4482

Syllabus

Competency R.C. 2152.58 discretionary transfer R.C. 2152.12 waiver of appealable errors by guilty plea amenable to care or rehabilitation in the juvenile justice system abuse of discretion meaningful review. Juvenile court erred in failing to hold a competency hearing and to issue a written determination regarding juvenile's competency as required under R.C. 2152.58. There was insufficient information in the record regarding the juvenile court's reasoning when ordering juvenile to be bound over to adult court for appellate court to determine whether the juvenile court abused its discretion in determining that juvenile was not amenable to care or rehabilitation in the juvenile justice system. Because the juvenile court (1) did not identify all of the factors it considered, (2) did not identify or discuss the factual or evidentiary basis for its determination that particular factors did or did not apply, and (3) did not explain its weighing of those factors, appellate court could not determine to what extent juvenile court's decision may have been based on erroneous facts and could not properly assess whether the juvenile court's decision was the product of a sound reasoning process or an unreasonable, arbitrary or unconscionable one.