State v. Jones

Citations

• 2022 Ohio 1169

Syllabus

Substantive due process fundamental fairness requirement equal protection rights R.C. 2152.10 R.C. 2152.12 R.C. 2152.121 juvenile discretionary transfer mandatory transfer adult court reverse bindover amenability hearing rational-basis test legitimate government purpose estoppel Juv.R. 1 R.C. 2152.02 and juvenile court's jurisdiction. Juveniles have no substantive right to an amenability hearing or to have their case returned to the juvenile court system following a discretionary transfer. Absent such rights, appellant's claim of a substantive due process violation lacked merit. After finding appellant met the initial statutory requirements for a discretionary transfer to adult court, the juvenile court completed a full investigation of appellant and held an amenability hearing where appellant and his counsel were present. At the conclusion of the hearing, the juvenile court stated its decision and reasoning to subject appellant to a discretionary transfer. The juvenile court issued a judgment entry that discussed its reasoning for transfer. Based upon these actions, appellant's alleged violation of the fundamental fairness requirement of procedural due process is without merit. The discretionary transfer statute is rationally related to the legitimate government purpose — to protect society from violent offenders and increase punishments for serious juvenile offenders — and, therefore, it does not violate appellant's equal protection rights. The juvenile court acted in accordance with Juv.R. 1, the discretionary transfer statute, and R.C. 2152.02 when it sent, by discretionary transfer, two of appellant's juvenile cases to adult court but retained jurisdiction over appellant's third juvenile case.