In re I.G.

2024 Ohio 2335
CourtOhio Court of Appeals
DecidedJune 12, 2024
Docket23CA27
StatusPublished

This text of 2024 Ohio 2335 (In re I.G.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re I.G., 2024 Ohio 2335 (Ohio Ct. App. 2024).

Opinion

[Cite as In re I.G., 2024-Ohio-2335.]

IN THE COURT OF APPEALS OF OHIO FOURTH APPELLATE DISTRICT PICKAWAY COUNTY

IN THE MATTER OF: : : I.G., : Case No. 23CA27 : AN ALLEGED : DELINQUENT CHLD. : : : : : DECISION AND JUDGMENT : ENTRY :

APPEARANCES:

Judy C. Wolford, Pickaway County Prosecuting Attorney, and Lynne R. Nothstine, Pickaway County Assistant Prosecuting Attorney, Circleville, Ohio, for Appellant.

Evan N. Wagner, Columbus, Ohio, for Appellee.

Smith, J.

{¶1} Appellant, the State of Ohio, appeals the trial court’s decision that

dismissed the delinquency complaint filed against Appellee, I.G. For the reasons

that follow, we sustain Appellant’s first assignment of error, overrule the second

assignment of error as moot, and reverse the trial court’s judgment.

FACTS Pickaway App. No. 23CA27 2

{¶2} On June 12, 2023, a law enforcement officer filed a sworn complaint

that alleged Appellee is a delinquent child for knowingly causing or attempting to

cause physical harm to another, in violation of R.C. 2903.13(A). The complaint

asserted that Appellee is 14 years of age and listed her date of birth as December

10, 2008.

{¶3} The officer also filed an affidavit containing the allegations forming

the basis for the complaint. This affidavit likewise states that Appellee’s date of

birth is December 10, 2008. Furthermore, the affidavit alleged that the delinquent

conduct occurred at Circleville Middle School and indicated that Appellee is a

student at the middle school.

{¶4} On June 30, 2023, Appellee appeared before the court and denied the

delinquency allegation. The trial court memorialized Appellee’s denial in a

“Judgment Entry on Initial Appearance.” This entry listed Appellee’s birth date as

December 10, 2008.

{¶5} Appellee filed a financial disclosure form that listed her date of birth

as December 10, 2008. Appellee certified that the information that she provided

on the form “is true to the best of [her] knowledge.” The trial court subsequently

appointed counsel to represent Appellee.

{¶6} On October 23, 2023, the trial court held an adjudication hearing.

A.H., the student Appellee allegedly assaulted, testified as follows. She is 14 years Pickaway App. No. 23CA27 3

of age and currently is homeschooled. Last school year, she attended Circleville

Middle School. She stated that on May 25, 2023, Appellee, another middle school

student, “hit [her] in the head really hard.”

{¶7} After A.H.’s testimony, Appellant rested. At that time, Appellee’s

counsel asserted that she did not believe “that the State proved jurisdiction as far as

[Appellee]’s age as being a juvenile.” Appellee thus requested the court to dismiss

the complaint “for lack of proof of jurisdiction.”

{¶8} Appellant countered that Appellee’s financial disclosure statement in

which she wrote her date of birth establishes the juvenile court’s jurisdiction.

Appellant pointed out that Appellee’s date of birth, December 10, 2008, shows that

she is under 18 years of age and thus within the juvenile court’s jurisdiction.

Appellee’s counsel asserted that Appellant could not rely on that document

because it was not notarized. The court stated that it would take the matter under

advisement.

{¶9} Appellee then presented character witnesses. The first witness, a

former middle school assistant principal, stated that he knew Appellee as a student

and described her as a “wonderful student.” Another witness, the middle school

counselor, likewise indicated that Appellee was a middle school student. The

middle school Language Arts Intervention Specialist, another middle school Pickaway App. No. 23CA27 4

intervention specialist, and a middle school teacher similarly testified that Appellee

was a middle school student.

{¶10} After the adjudicatory hearing, the court permitted the parties to

submit written arguments regarding Appellee’s motion to dismiss the complaint.

Appellee asserted that Appellant failed “to prove age jurisdiction at the

adjudicatory trial.” Appellee recognized that this court held, in In re S.S., 4th Dist.

Vinton No. 10CA682, 2011-Ohio-4081, that an indigency affidavit suffices to

establish the individual’s age. Appellee contended, however, that at the time we

decided S.S., indigency affidavits were required to be notarized or sworn.

Appellee asserted that since our 2011 S.S. decision, the rules have changed, and

financial disclosure forms no longer need to be sworn under oath and notarized.

She cited Juv.R. 29(E)(3), which requires testimony to be “under oath or

affirmation,” and argued that Appellant could not rely upon an unsworn,

unnotarized document to prove her age. Appellee thus claimed that Appellant

failed to present competent evidence demonstrating that she is less than 18 years of

age. Appellee argued that the court, therefore, must dismiss the complaint.

{¶11} Appellant countered that “by appearing and proceeding with the

adjudication trial on October 23, 2023,” Appellee waived the argument that the

court lacked personal jurisdiction over her due to Appellant’s alleged failure to

establish her age. Appellant further asserted that the record contained sufficient Pickaway App. No. 23CA27 5

proof that Appellee is under 18 years of age. Appellant disputed Appellee’s claim

that her financial disclosure form was not competent evidence to establish her age.

Appellant pointed out that our S.S. decision did not indicate that the state must

establish age by means of sworn statements or testimony under oath.

{¶12} Appellant also argued that Appellee’s financial disclosure form was

“reliable enough for the court to appoint counsel based upon that information,” and

thus, “it is likewise reliable enough to prove the child’s age.” Appellant

additionally asserted that “a juvenile’s age may be proved by evidence other than

sworn testimony.” Appellant contended that a court could rely upon observing the

child in person and deducing that the child is under 18 years of age. Appellant

stated that Appellee “appeared before the court at least three times during the

pendency of the proceeding, so th[e] court had ample opportunity to observe that

she is a juvenile.”

{¶13} The trial court did not agree with any of Appellant’s arguments. The

court did not find our decision in S.S. to be dispositive. Instead, the court

distinguished that case by noting that in 2011, “an individual had to submit a

sworn, notarized Affidavit which would have included the juvenile’s date of birth.”

Since that time, however, the “form was modified to a Financial Disclosure Form

which is not a sworn, notarized Affidavit.” The court further noted that “Juv.R.

29(E)(3) mandates that evidence should be submitted under oath or affirmation.” Pickaway App. No. 23CA27 6

{¶14} The court also rejected Appellant’s argument that Appellee submitted

to the court’s personal jurisdiction. The court determined that in S.S., this court

had refused to follow those appellate courts that have held that failure to raise the

issue before the adjudication hearing results in a waiver. The trial court stated:

“The Fourth District has long held that the establishment of age relates to the

jurisdiction of the juvenile court with proof of age being adduced at any time

[during] the proceeding.”

{¶15} The court found that Appellant failed to “present any testimony at the

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