May Juvenile Conviction With Sentence of Treatment Be Used to Enhance Later Adult Criminal Charges?
Jason T. Bode v. State of Ohio, Case no. 2013-1044
Fifth District Court of Appeals (Fairfield County)
ISSUE: May a juvenile conviction for operating a vehicle under the influence of alcohol (OVI) be used to enhance later OVI charges when, during the juvenile proceeding, the juvenile did not have an attorney, did not formally waive his right to counsel, and was sentenced to a three-day treatment program?