State v. Jackson

Citations

• 2020 Ohio 80

Syllabus

JUVENILE – BINDOVER – APPELLATE REVIEW/CRIMINAL – SENTENCING – COUNSEL – JAIL-TIME CREDIT: Where the juvenile was charged with offenses that were subject to a mandatory bindover, and where the juvenile stipulated to the existence of probable cause and waived a probable-cause hearing, the juvenile court did not err in transferring jurisdiction of the case to adult court. Where the trial court imposed an agreed sentence that was authorized by law, the sentence was not subject to review on appeal pursuant to R.C. 2953.08(D)(1). Trial counsel was not ineffective for stipulating to the existence of probable cause and waiving a probable-cause hearing prior to the transfer of jurisdiction from juvenile court to adult court: defendant was not prejudiced where the record contains no indication that the state lacked sufficient evidence to prove his guilt or that the juvenile court would not have found probable cause that defendant had committed the offenses. The trial court committed plain error where it failed to award defendant jail-time credit for the time he spent confined in a juvenile facility prior to the transfer of jurisdiction of his case from juvenile court to adult court.