Was Juvenile Offender 'Apprehended' Before 21st Birthday By Filing of Juvenile Court Complaint and Service of Summons?
For Offenses Allegedly Committed When Defendant Was Between Nine and 14 Years Old
State of Ohio v. Matthew Lindstrom, Case no. 2012-0252
Eighth District Court of Appeals (Cuyahoga County)
ISSUE: Does a state law that keeps crimes committed by juveniles under the jurisdiction of a juvenile court if the defendant is "taken into custody or apprehended" for a juvenile offense before his 21st birthday apply to a case in which a delinquency complaint was filed in juvenile court, a summons was issued by the juvenile court and the summons was served on the defendant before his 21st birthday, but the defendant was never placed under arrest and did not make a first appearance in court until after he turned 21?