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State v. Aalim - 2017-Ohio-2956, 150 Ohio St. 3d 489, 83 N.E.3d 883

Rule:

The mandatory bindover of certain juvenile offenders under R.C. 2152.10(A)(2)(b) and 2152.12(A)(1)(b) complies with due process and equal protection as guaranteed by the Ohio and United States Constitutions.

Facts:

On Dec. 3, 2013, appellee, the State of Ohio, filed a complaint in the Juvenile Division of the Montgomery County Court of Common Pleas (Division), alleging that appellant, Matthew I. Aalim, engaged in conduct that would be considered aggravated robbery in violation of R.C. 2911.01(A)(1) if committed by an adult. The complaint also contained a firearm specification. The State filed a motion to transfer Aalim, requesting that the juvenile court relinquish jurisdiction and transfer him to the general division of the common pleas court to be tried as an adult pursuant to Juv.R. 30R.C. 2152.10(A)(2)(b), and R.C. 2152.12(A)(1)(b). On Jan. 10, 2014, Aalim appeared before the Division for a hearing on whether the juvenile court should relinquish jurisdiction over Aalim's case. After the hearing, the juvenile court issued an order and entry finding that Aalim was 16 years old at the time of the alleged offense and that there was probable cause to believe that he had committed the conduct alleged in the complaint, including the firearm specification. Based on these findings, the juvenile court recognized that it no longer had jurisdiction and transferred the case to the general division of the common pleas court as required under R.C. 2152.10(A)(2)(b) and 2152.12(A)(1)(b). An indictment was issued charging Aalim with two counts of aggravated robbery in violation of R.C. 2911.01(A)(1) with accompanying firearm specifications. The two counts of aggravated robbery charged in the indictment reflected the fact that there were two victims of the alleged conduct. Aalim filed a motion to dismiss the indictment and transfer his case back to juvenile court, arguing that mandatory bindover of juveniles pursuant to R.C. 2152.10(A)(2)(b) and 2152.12(A)(1)(b) violated their rights to due process and equal protection as well as the prohibition against cruel and unusual punishments under both the United States and Ohio Constitutions. The trial court overruled the motion, and Aalim entered pleas of no contest to the two counts of aggravated robbery. The court accepted the pleas, dismissed the firearm specifications consistently with a plea agreement that the parties had reached, and sentenced Aalim to concurrent prison terms of four years on each count. An appellate court affirmed the trial court's judgment, rejecting Aalim's challenges to the mandatory-bindover statutes.

Issue:

Did the mandatory bindover of juveniles pursuant to R.C. 2152.10(A)(2)(b) and 2152.12(A)(1)(b) violate Aalim's rights to due process and equal protection as well as the prohibition against cruel and unusual punishments under both the United States and Ohio Constitutions?

Answer:

No.

Conclusion:

The state supreme court held that the mandatory bindover of certain juvenile offenders under R.C. 2152.10(A)(2)(b) and2152.12(A)(1)(b) did not violate substantive or procedural due process under U.S. Const. amend. XIV and Ohio Const. art. I, § 16, as an amenability hearing was not rooted in the nation's history and tradition and implicit in the concept of ordered liberty, and the mandatory bindover from the juvenile division to the general division of the common pleas court satisfied the requirements of "fundamental fairness." Furthermore, the court held that the statutes did not violate equal protection under the federal Constitution's Fourteenth Amendment and Ohio Const. art. I, § 2, as the mandatory-bindover statutory scheme was rationally related to the legitimate governmental purpose of increased punishments for serious juvenile offenders.

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