In re J.K.

2013 Ohio 4938
Ohio Court of Appeals·Decided November 8, 2013·No. C-120857·Published·Cited by 1 cases

Opinion

[Cite as In re J.K., 2013-Ohio-4938.]

IN THE COURT OF APPEALS FIRST APPELLATE DISTRICT OF OHIO HAMILTON COUNTY, OHIO

IN RE: J.K. : APPEAL NO. C-120857 TRIAL NO. 11-6382z :

: O P I N I O N.

Civil Appeal From: Hamilton County Juvenile Court

Judgment Appealed From Is: Reversed and Cause Remanded

Date of Judgment Entry on Appeal: November 8, 2013

Joseph T. Deters, Hamilton County Prosecuting Attorney, and Philip R. Cummings, Assistant Prosecuting Attorney, for Appellant,

Gordon G. Magella, for Appellee.

Please note: this case has been removed from the accelerated calendar. OHIO FIRST DISTRICT COURT OF APPEALS

S YLVIA S IEVE H ENDON , Presiding Judge.

{¶1} The state of Ohio appeals the juvenile court’s judgment dismissing this case

against J.K., a juvenile, who was charged with committing an act that would be a robbery

offense if committed by an adult. Because the dismissal was improper as a matter of law, we

reverse the court’s judgment and remand this case for further proceedings.

No Delays Were Precipitated by the State

{¶2} On July 1, 2011, J.K. was arrested for robbing another child on the previous

day. He was released and ordered to appear in the Hamilton County Juvenile Court on July

28, 2011.

{¶3} On July 28, 2011, J.K. entered a plea of denial and filed a request for

discovery pursuant to Juv.R. 24. He was ordered to appear on August 25, 2011, for trial.

{¶4} On August 11, 2011, the state filed a request for discovery as well as its

response to the discovery request by the defense. The state’s response to the request

included witnesses’ names and their expected testimony. In addition, the state provided a

recording of J.K’s oral statement to police, wherein he admitted to robbing the victim, a boy

named David, whom he knew from his neighborhood.

{¶5} On August 24, 2011, defense counsel filed a motion to compel discovery

pursuant to Juv.R. 24(B), which allows a party to apply to the court for a written order

granting the discovery if “a request for discovery has been made and refused.” In its motion,

the defense asserted that the state had failed to provide “any and all police reports and

supplements, and any written summary or statement of or by any witness (including police

officers) or alleged victim except that which is work product of counsel.” The defense had

not asked for those materials in its initial discovery request.

2 OHIO FIRST DISTRICT COURT OF APPEALS

{¶6} On August 25, 2011, a magistrate of the juvenile court held a hearing on the

defense motion. At that time, the defense acknowledged that the state had provided a “527”

(arrest and investigation) police report. The defense argued, though, that it was also

entitled to a “301” police (incident) report. The state argued that the 301 report was not

discoverable.

{¶7} At the hearing, defense counsel examined Cincinnati Police Detective

Longworth, who had been assigned to investigate the robbery in this case. He testified that

he had received a 301 incident report prepared by Cincinnati Police Officer Mayhams, who

had responded to the victim’s complaint. The detective testified that the information in

such a report may come from a number of sources, and not necessarily from the victim.

{¶8} The detective testified that he had interviewed the victim, who had assisted

him in identifying J.K. Shortly thereafter, J.K. was arrested and interviewed, and then

charged with robbery. The detective testified that he had prepared the 527 arrest and

investigation report.

{¶9} Although Officer Mayhams, who had prepared the 301 report, was present at

the hearing, defense counsel declined to call him in support of the motion to compel. The

magistrate continued the hearing on the motion for two weeks so that the parties could

submit memoranda in support of their positions.

{¶10} On September 8, 2011, the magistrate issued an order finding that the 301 report was discoverable because it would have been discoverable under Crim.R. 16, had the

defendant been an adult. The state filed a timely motion to set aside the magistrate’s order,

pursuant to Juv.R. 40(D)(2)(b).

{¶11} On October 25, 2011, a visiting judge heard arguments on the state’s motion and continued the matter several times for a ruling. The judge allowed J.K. to remain at

home in the interim.

3 OHIO FIRST DISTRICT COURT OF APPEALS

{¶12} On November 28, 2011, the visiting judge again continued the case for a ruling on the motion. The judge noted that J.K. was being held in detention for other

charges, and that J.K. was “not being held on the [r]obbery charge at this time.”

{¶13} On January 19, 2012, the visiting judge issued a ruling on the state’s motion to set aside the magistrate’s order. Initially, the judge noted that “the defendant never

responded in any way to the state’s reciprocal discovery request.” In ruling on the motion,

the judge rejected the magistrate’s determination that the entire 301 report was

discoverable, but adopted the magistrate’s order that the defense was entitled to any

transcriptions or summaries of oral statements of the defendant or witnesses. In doing so,

the judge noted that “the oral statement must be attributed to a party or witness.” The

judge concluded by modifying the magistrate’s order to provide that “the state may redact

portions of the police officer notes or reports that are not transcriptions or summaries of the

defendant or witnesses.” The judge continued the matter “for completion of discovery” and

for a pretrial hearing before a magistrate.

{¶14} At a pretrial hearing on February 2, 2012, the state informed the magistrate that its discovery response was complete and that the 301 report did not include statements

or summaries of statements attributable to a particular witness. The magistrate’s order

from that hearing stated that if the 301 report had been “based solely on police interviews[,]

* * * that report is discoverable, whether the witness is named or not.” At the request of

defense counsel, the magistrate continued the case for another pretrial hearing.

{¶15} Before the February 9, 2012, pretrial hearing, the state provided the defense with a redacted copy of the 301 report. According to the state, the redacted information in

the report did not include names of witnesses. The magistrate’s order from that hearing

reflected that the defense was satisfied that discovery had been completed. The magistrate

continued the matter to March 8, 2012, for trial.

4 OHIO FIRST DISTRICT COURT OF APPEALS

The Defense Filed a Baseless Motion in Limine

{¶16} Two days before trial, the defense filed a motion to suppress J.K.’s statements to police, as well as a motion in limine to prohibit an in-court identification of J.K. by the

robbery victim. The motion in limine alleged that the identification of J.K. at trial “would

have no independent basis, would be unnecessarily suggestive, and would be conducive to

irreparable mistaken identification.” The motion alleged that the victim, David, had been

robbed “by several unknown suspects. No other description was provided by David. [J.K.]

was not an unknown person to David” on the date of the offense. The defense later

supplemented its motion in limine to allege that the only description of the suspects

provided by David was “male black,” and that “Detective Longworth drove David around to

look for suspects; [J.K.] was pointed out and arrested.”

Free access — add to your briefcase to read the full text and ask questions with AI

In re J.K., 2013 Ohio 4938 (Ohio Ct. App. 2013).

2013 Ohio 4938 (In re J.K.) — published by Counsel Stack Legal Research, free access to 12M+ legal documents.

Related

In re T.D.
2014 Ohio 1752 (Ohio Court of Appeals, 2014)