In re Order Requiring Fingerprinting of a Juvenile

537 N.E.2d 1286, 42 Ohio St. 3d 124, 1989 Ohio LEXIS 55
CourtOhio Supreme Court
DecidedMay 3, 1989
DocketNo. 88-5
StatusPublished
Cited by13 cases

This text of 537 N.E.2d 1286 (In re Order Requiring Fingerprinting of a Juvenile) is published on Counsel Stack Legal Research, covering Ohio Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In re Order Requiring Fingerprinting of a Juvenile, 537 N.E.2d 1286, 42 Ohio St. 3d 124, 1989 Ohio LEXIS 55 (Ohio 1989).

Opinions

Alice Robie Resnick, J.

The sole issue presented in this case is: Under what circumstances may a juvenile court judge order the fingerprinting of a juvenile pursuant to R.C. 2151.313 (A)(1)?

R.C. 2151.313 provides in pertinent part:

“(A)(1) Except as provided in division (A)(2) of this section, no child shall be fingerprinted or photographed in the investigation of any violation of law without the consent of the juvenile judge.
“(2) Fingerprints and photographs of a child may be taken by law enforcement officers when the child is arrested or otherwise taken into custody for the commission of an act that would be a felony if committed by an adult, without the consent of the juvenile judge, when there is probable cause to believe that the child may have been involved in the commission of the act. A law enforcement officer who takes fingerprints or photographs of a child under this division immediately shall inform the juvenile court that the fingerprints or photographs were taken, and shall provide the court with the identity of the child, the number of fingerprints and photographs taken, and the name and address of each person who has custody and control of the fingerprints or photographs or copies of the fingerprints or photographs.”

Juvenile proceedings are not crimi[126]*126nal in nature. State v. Carder (1966), 9 Ohio St. 2d 1, 11, 38 O.O. 2d 1, 7, 222 N.E. 2d 620, 627; State v. Davis (1978), 56 Ohio St. 2d 51, 10 O.O. 3d 87, 381 N.E. 2d 641. However, it is well-settled that a juvenile is as entitled as an adult to the constitutional protections of the Fourth Amendment. Id. at 56, 10 O.O. 3d at 90, 381 N.E. 2d at 645. The taking of the juvenile into custody for the purpose of obtaining nontestimonial evidence, such as fingerprints, is clearly within the scope of the Fourth Amendment to the United States Constitution and Section 14, Article I of the Ohio Constitution. “Detentions for the sole purpose of obtaining fingerprints are no less subject [than other investigatory detentions] to the constraints of the Fourth Amendment. * * *” Davis v. Mississippi (1969), 394 U.S. 721, 727. The crucial question then is whether this intrusion can be constitutionally justified in the absence of a finding of probable cause.

The United States Supreme Court in Hayes v. Florida (1985), 470 U.S. 811, 817, in addressing circumstances when fingerprinting may be constitutionally permissible, stated:

“We also do not abandon the suggestion in Davis [v. Mississippi (1969), 394 U.S. 721] and Dunaway [v. New York (1979), 442 U.S. 200] that under circumscribed procedures, the Fourth Amendment might permit the judiciary to authorize the seizure of a person on less than probable cause and his removal to the police station for the purpose of fingerprinting. We do not, of course, have such a case before us. We do note, however, that some States, in reliance on the suggestion in Davis, have enacted procedures for judicially authorized seizures for the purpose of fingerprinting. The state courts are not in accord on the validity of these efforts to insulate investigative seizures from Fourth Amendment invalidation. Compare People v. Madson, 638 P. 2d 18, 31-32 (Colo. 1981), with State v. Evans, 215 Neb. 433, 438-439, 338 N.W. 2d 788, 792-793 (1983), and In re an Investigation into Death of Abe A., 56 N.Y. 2d 288, 295-296, 437 N.E. 2d 265, 269 (1982).” (Footnote omitted.)

The court in People v. Madson (Colo. 1981), 638 P. 2d 18, 31-32, in discussing the Colorado statute enacted to permit fingerprinting and other methods of nontestimonial identification on less than probable cause, stated:

“Crim. P. 41.1 was an outgrowth of dicta in Davis v. Mississippi, 394 U.S. 721, 89 S. Ct. 1394, 22 L. Ed. 2d 676 (1969), suggesting that limited intrusions based on less than probable cause might be constitutionally permissible under narrowly defined circumstances. Subsequent cases of the United States Supreme Court have addressed the propriety of such intrusions in various contexts. See, e.g., Michigan v. Summers, [452] U.S. [692], 101 S. Ct. 2587, 69 L. Ed. 2d 340 (1981); United States v. Cortez, 449 U.S. 411, 101 S. Ct. 690, 66 L. Ed. 2d 621 (1981); United States v. Brignoni-Ponce, 422 U.S. 873, 95 S. Ct. 2574, 45 L. Ed. 2d 607 (1975); Adams v. Williams, 407 U.S. 143, 92 S. Ct. 1921, 32 L. Ed. 2d 612 (1972); Terry v. Ohio [(1969), 392 U.S. 1]. These cases suggest that limited intrusions into privacy on less than probable cause are reconcilable with Fourth Amendment guarantees when the following conditions exist. First, there must be an articulable and specific basis in fact for suspecting criminal activity at the outset. Second, the intrusion must be limited in scope, purpose and duration. Third, the intrusion must be justified by substantial law enforcement interests. Last, there must be an oppor[127]*127tunity at some point to subject the intrusion to the neutral and detached scrutiny of a judicial officer before the evidence obtained therefrom may be admitted in a criminal proceeding against the accused.”

Other states have also followed the dicta of both Davis v. Mississippi, supra, and Hayes v. Florida, supra, by enacting statutes and rules authorizing their courts to compel a person who is no more than a suspect to come forward and supply nontestimonial evidence. See 5A Ariz. Rev. Stat. Ann. Section 13-3905; 4A Idaho Code Section 19-625; N.C. Gen. Stat. Section 15A-271 et seq.; Utah Code Ann. Section 77-8-1 (lineups only).

However, R.C. 2151.313(A)(1) appears to require immediate participation by the juvenile court judge, whereas in Madson, supra, it was held: “Last, there must be an opportunity at some point to subject the intrusion to the neutral and detached scrutiny of a judicial officer before the evidence obtained therefrom may be admitted in a criminal proceeding against the accused.” (Emphasis added.) Id at 32. In State v. Davis, supra, this court stated that “ ‘[t]he purpose of * * * [R.C. 2151.31 now 2151.313] is not to determine * * * admissibility into evidence [of fingerprints] but rather to conform to the theory that juvenile proceedings are not criminal in nature.’ ” Id. at 56, 10 O.O. 3d at 90, 381 N.E. 2d at 645. Therefore, the last factor of Madson has no relevance to the validity of an order issued pursuant to R.C. 2151.313.

R.C. 2151.313, when read in its entirety, appears to permit a juvenile court judge to order fingerprinting without finding probable cause in certain situations.

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

Related

Patrick v. Patrick
2026 Ohio 450 (Ohio Court of Appeals, 2026)
Bertalan v. Bertalan
2025 Ohio 1443 (Ohio Court of Appeals, 2025)
Parsai v. Parsai
2025 Ohio 829 (Ohio Court of Appeals, 2025)
United States v. Askew
529 F.3d 1119 (D.C. Circuit, 2008)
State v. Kyle, Unpublished Decision (11-7-2005)
2005 Ohio 5890 (Ohio Court of Appeals, 2005)
In re Nontestimonial Identification Order Directed to R.H.
762 A.2d 1239 (Supreme Court of Vermont, 2000)
In Re RH
762 A.2d 1239 (Supreme Court of Vermont, 2000)
In Re Nicholson
724 N.E.2d 1217 (Ohio Court of Appeals, 1999)
ALFREDO A. v. Superior Court
865 P.2d 56 (California Supreme Court, 1994)
City of Zanesville v. Osborne
597 N.E.2d 1200 (Ohio Court of Appeals, 1992)
State v. Marut
579 N.E.2d 281 (Ohio Court of Appeals, 1989)

Cite This Page — Counsel Stack

Bluebook (online)
537 N.E.2d 1286, 42 Ohio St. 3d 124, 1989 Ohio LEXIS 55, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-order-requiring-fingerprinting-of-a-juvenile-ohio-1989.