completion-of-disposition hearing in Ohio

2026In this regard, “the discretion employed by a juvenile court at the initial classification hearing 8 OHIO FIRST DISTRICT COURT OF APPEALS serves a purpose different from the discretion employed at the completion-of- disposition hearing.” Id. {¶25} We review the juvenile court’s decision to continue, modify, or end a child’s classification for an abuse of discretion.

2025The lack of discretion at the completion-of-disposition hearing rendered the statute unconstitutional as applied to those mandatory juvenile-offender registrants who had been classified as Tier I offenders. 8 OHIO FIRST DISTRICT COURT OF APPEALS {¶20} The Supreme Court pointed out in In re D.R., 2022-Ohio-4493 , that the discretion employed by the juvenile court at the initial classification hearing, which is at issue in this case, serves a different purpose than the discretion employed at the completion-of-disposition hearing at issue in In re D.R.

2022Id. at ¶ 10, citing In re C.P., 131 Ohio St.3d 513 , 2012-Ohio-1446 , 967 N.E.2d 729 , and State v. D.H., 120 Ohio St.3d 540 , 2009-Ohio-9 , 901 N.E.2d 209 . {¶ 11} The appellate court reversed the juvenile court’s judgment and remanded the cause for a new completion-of-disposition hearing to allow the juvenile court to exercise its discretion to continue D.R.’s Tier I classification or to “declassify” him.

2022Id. at ¶ 10, citing In re C.P., 131 Ohio St.3d 513 , 2012-Ohio-1446 , 967 N.E.2d 729 , and State v. D.H., 120 Ohio St.3d 540 , 2009-Ohio-9 , 901 N.E.2d 209 . {¶ 11} The appellate court reversed the juvenile court’s judgment and remanded the cause for a new completion-of-disposition hearing to allow the juvenile court to exercise its discretion to continue D.R.’s Tier I classification or to “declassify” him.

2022In re N.D., 2021-Ohio-4506 , 182 N.E.3d 470 , ¶ 32, 44 (5th Dist.), appeal allowed by 166 Ohio St.3d 1467 , 2022-Ohio-1163 , 185 N.E.3d 106 .

2022(No. 2022-0107―Submitted December 23, 2022―Decided December 28, 2022.) APPEAL from the Court of Appeals for Licking County, Nos. 21 CA 0040 and 21 CA 0041, 2021-Ohio-4506 . _________________ {¶ 1} The judgment of the court of appeals is reversed on the authority of In re D.R., __ Ohio St.3d __, 2022-Ohio-4493 , __ N.E.3d __, and the cause is remanded to the juvenile court to conduct a new completion-of-disposition hearing that takes into account the holding in D.R.

2019Jean-Baptiste v. Kirsch, 134 Ohio St.3d 421 , 2012-Ohio-5697 , 983 N.E.2d 302 , in which the court held that the juvenile court lacked statutory authority to conduct an initial juvenile-offender-registration hearing after the juvenile had fully satisfied the court’s delinquency adjudication and had turned 21.

2019Jean-Baptiste v. Kirsch, 134 Ohio St.3d 421 , 2012-Ohio-5697 , 983 N.E.2d 302 , in which the court held that the juvenile court lacked statutory authority to conduct an initial juvenile-offender-registration hearing after the juvenile had fully satisfied the court’s delinquency adjudication and had turned 21.

2022D.R.’s Tier I classification, which constitutes a punishment for his juvenile delinquency, see State v. Williams, 129 Ohio St.3d 344 , 2011-Ohio-3374 , 952 N.E.2d 1108, ¶ 10-21 , is continued into his adulthood automatically. {¶ 30} Although the registration and notification procedures may have been harsher in In re C.P. than those at issue today, it was the automatic nature of the process in that case that offended due process. 131 Ohio St.3d 513 , 2012-Ohio- 1446, 967 N.E.2d 729 , at ¶ 85.

2022D.R.’s Tier I classification, which constitutes a punishment for his juvenile delinquency, see State v. Williams, 129 Ohio St.3d 344 , 2011-Ohio-3374 , 952 N.E.2d 1108, ¶ 10-21 , is continued into his adulthood automatically. {¶ 30} Although the registration and notification procedures may have been harsher in In re C.P. than those at issue today, it was the automatic nature of the process in that case that offended due process. 131 Ohio St.3d 513 , 2012-Ohio- 1446, 967 N.E.2d 729 , at ¶ 85.

2022Because the two goals do not perfectly align, D.R. received “the worst of both worlds,” Kent, 383 U.S. at 556 , 86 S.Ct. 1045 , 16 L.Ed.2d 84 , under the fundamentally unfair application of R.C. 2152.84(A)(2)(b) to his case. {¶ 34} Because of D.R.’s age when he committed his sexually oriented offense, the juvenile court was effectively prohibited by R.C. 2152.84(A)(2)(b) from exercising its discretion at the completion-of-disposition hearing to either continue D.R.’s Tier I classification beyond age 18 or terminate the classification upon a finding of good cause, since D.R. had been adjudged s

2022Because the two goals do not perfectly align, D.R. received “the worst of both worlds,” Kent, 383 U.S. at 556 , 86 S.Ct. 1045 , 16 L.Ed.2d 84 , under the fundamentally unfair application of R.C. 2152.84(A)(2)(b) to his case. {¶ 34} Because of D.R.’s age when he committed his sexually oriented offense, the juvenile court was effectively prohibited by R.C. 2152.84(A)(2)(b) from exercising its discretion at the completion-of-disposition hearing to either continue D.R.’s Tier I classification beyond age 18 or terminate the classification upon a finding of good cause, since D.R. had been adjudged s

2022(No. 2021-0934—Submitted May 25, 2022—Decided December 16, 2022.) APPEAL from the Court of Appeals for Hamilton County, No. C-190594, 2021-Ohio-1797 .

2022The court of appeals remanded the case for a new completion-of-disposition hearing to allow the juvenile court to exercise discretion to continue D.R.’s Tier I juvenile-offender- registrant classification or to “declassify” him. 2021-Ohio-1797 , 173 N.E.3d 103 , ¶ 17.

2022Id. at ¶ 10, citing In re C.P., 131 Ohio St.3d 513 , 2012-Ohio-1446 , 967 N.E.2d 729 , and State v. D.H., 120 Ohio St.3d 540 , 2009-Ohio-9 , 901 N.E.2d 209 . {¶ 11} The appellate court reversed the juvenile court’s judgment and remanded the cause for a new completion-of-disposition hearing to allow the juvenile court to exercise its discretion to continue D.R.’s Tier I classification or to “declassify” him.

2022Id. at ¶ 10, citing In re C.P., 131 Ohio St.3d 513 , 2012-Ohio-1446 , 967 N.E.2d 729 , and State v. D.H., 120 Ohio St.3d 540 , 2009-Ohio-9 , 901 N.E.2d 209 . {¶ 11} The appellate court reversed the juvenile court’s judgment and remanded the cause for a new completion-of-disposition hearing to allow the juvenile court to exercise its discretion to continue D.R.’s Tier I classification or to “declassify” him.

2020Bd. of Revision, 64 Ohio St.2d 20, 22 , 412 N.E.2d 947 (1980). {¶ 43} This does not mean that the juvenile court may conduct the completion-of-disposition hearing any time it wants as long as the registration order 14 January Term, 2020 remains in effect.

2020Bd. of Revision, 64 Ohio St.2d 20, 22 , 412 N.E.2d 947 (1980). {¶ 43} This does not mean that the juvenile court may conduct the completion-of-disposition hearing any time it wants as long as the registration order 14 January Term, 2020 remains in effect.

2020The effect of the completion-of-disposition hearing on the initial classification order {¶ 45} The First District held that because the juvenile court did not hold the completion-of-disposition hearing before R.B.’s disposition ended, R.B. was no longer under a valid classification order. 2019-Ohio-3298 at ¶ 14 .

2017Further, at the reclassification hearing, the trial court must determine whether the specific tier classification in which the child has been placed is proper and if it should be continued or modified. {¶8} We held in State v. Schulze, 2016-Ohio-470 , 59 N.E.3d 673 (1st Dist.), that where the juvenile court had correctly held the initial classification hearing under Megan’s Law, but had erroneously held the completion-of- disposition hearing under the Adam Walsh Act, the order entered after the second hearing classifying Schulze under the Adam Walsh Act was void, and there was no valid order i