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Saturday, November 23, 2024

Ohio Supreme Court allows teen's tampering charge after transfer to adult court

State Supreme Court
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Justice Michael P. Donnelly | Ohio Supreme Court Website

A teenager, Timothy Williams, may face charges of tampering with evidence in the Hamilton County Common Pleas Court after his murder case was transferred from juvenile court. This decision follows a ruling by the Supreme Court of Ohio, which reversed an earlier decision by the First District Court of Appeals. The Appeals Court had determined that Williams could not be charged in adult court for offenses not transferred during a bindover proceeding.

In April 2020, Williams, then 16 years old, shot Leslie Lawson and subsequently sold the gun used in the incident. Initially charged in juvenile court with crimes equivalent to murder and felonious assault if committed by an adult, his case was later moved to adult court where he faced an additional charge of tampering with evidence.

Justice Patrick F. Fischer explained that according to the Supreme Court’s 2022 State v. Burns decision, a juvenile can be charged in adult court for acts related to those initially filed in juvenile court. "The charge is rooted in the same acts that were the subject of the juvenile complaint," stated Justice Fischer regarding Williams’ tampering charge.

The principle of stare decisis was cited as justification for applying this rule to Williams' case. Justice Fischer noted that despite changes made by the General Assembly following other relevant decisions like State v. Smith, no alterations were made to affect Burns' application.

Chief Justice Sharon L. Kennedy concurred but expressed disagreement with Burns and Smith's interpretations of bindover laws, advocating for their reversal due to what she described as "clearly erroneous interpretation of a statute." Her opinion was supported by Justice R. Patrick DeWine and Judge Jeffrey M. Welbaum.

Williams pleaded guilty to involuntary manslaughter and tampering with evidence, receiving a sentence totaling 17 years. Despite his plea, he appealed against the tampering conviction on grounds it was not initially presented in juvenile court—a stance upheld by the First District but overturned upon appeal by prosecutors to the Supreme Court.

The Supreme Court clarified through its review that once probable cause is established for any charge at a juvenile level, subsequent related charges can be pursued in adult court if they are rooted in initial allegations.

The decision reaffirmed Burns and maintained that Williams' actions justified facing additional charges post-transfer due to their connection with his original offenses.

Chief Justice Kennedy argued against jurisdictional limitations imposed by previous decisions, asserting they do not align with statutory language governing case transfers from juvenile courts.

"Neither of the jurisdictional limitations from Smith and Burns can reasonably be drawn from the plain language of the bindover statutes," she stated while supporting Williams’ indictment under current law interpretations despite her objections to prior rulings.

This case underscores ongoing debates about how legal precedents influence charging juveniles as adults when cases involve serious offenses or complex legal considerations post-transfer from juvenile systems.

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