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Charge against teen may proceed in adult court

By Dan Trevas
Court News Ohio

A teen may be charged and convicted of tampering with evidence in the Hamilton County Common Pleas Court after his murder case was transferred from juvenile court, the Supreme Court of Ohio ruled.

The Supreme Court reversed the First District Court of Appeals, which found that then 16-year-old Timothy Williams could not face a charge in adult court that the juvenile court did not transfer during a bindover proceeding.

In April 2020, Williams shot Leslie Lawson to death. He sold the gun he used days later. When caught, Williams’ case was initiated in juvenile court, and he was charged with crimes that, if he were an adult, would be murder and felonious assault. After the juvenile court transferred his case to adult court, a grand jury indicted Williams with the added charge of tampering with evidence.

Writing for the Court majority, Justice Patrick F. Fischer explained that under the Supreme Court’s  2022 State v. Burns decision, a juvenile could face a charge in adult court that was not charged originally in juvenile court if “the charge is rooted in the same acts that were the subject of the juvenile complaint.” Williams’ tampering with evidence charge was rooted in the murder charge because Williams had disposed of the murder weapon, the Court concluded.

Under the principle of stare decisis, the Court stated that the rule adopted in Burns should apply to Williams. Justice Fischer noted that the General Assembly has changed the bindover law to adopt the Court’s decision 2022 State v. Smith decision, which was the foundation for Burns. And he recognized that the General Assembly had not changed the bindover law after Smith to affect the Court’s decision in Burns.

Justices Michael P. Donnelly, Melody Stewart, and Jennifer Brunner joined Justice Fischer’s opinion.

In a concurring opinion, Chief Justice Sharon L. Kennedy wrote that under the prior version of the juvenile bindover law, R.C. 2151.23(H), the adult court was empowered to add the tampering with evidence charge regardless of whether the juvenile court considered it or if it was rooted in acts the juvenile faced in the juvenile court complaint. She urged the Court to overturn Burns and Smith, stating that stare decisis should not be invoked where there is a “clearly erroneous interpretation of a statute.”

Justice R. Patrick DeWine joined Chief Justice Kennedy’s opinion. Second District Court of Appeals Judge Jeffrey M. Welbaum, sitting for Justice Joseph T. Deters, also joined the chief justice’s opinion.

Williams agreed to help settle a dispute with Jamal Lawson. Williams and his friend borrowed Grace Jacobs’ car, telling her they needed it to visit someone on the other side of town. Williams rang the doorbell of the home of Everett and Leslie Lawson, Jamal’s parents, and yelled to them for help, pretending to have been injured in a car accident. Leslie opened the front door while her husband dialed 911. Williams shot Leslie twice, killing her instantly.

Jacobs would later testify that when Williams and his friend returned her car, she saw they had a gun. After seeing Lawson’s murder on the news, Jacobs asked them about the murder, and Williams told her he would “take the charge.”

Vincent Thompson told police that Williams sold him a “hot” gun days after the murder.

The Hamilton County Prosecutor’s Office filed a complaint in juvenile court, charging that Williams committed two crimes that, if he were an adult, would be murder and felonious assault and that both charges included a gun specification.

Because of the nature of the crime and Williams’ age, the juvenile court conducted a bindover hearing. The juvenile court found probable cause that Williams committed the crimes and transferred the case to common pleas court. After the case was transferred to adult court, a grand jury indicted Williams for murder, felonious assault, and tampering with evidence for knowingly disposing of the gun to impair law enforcement’s ability to use it as evidence against him.

Williams agreed to plead guilty to involuntary manslaughter and tampering with evidence. He was sentenced to 14 years in prison for involuntary manslaughter with a gun specification and an additional three years for tampering with evidence.

Although he pleaded guilty, Williams appealed his tampering with evidence conviction to the First District. He argued his rights were violated because he was indicted on a charge that had not been transferred from juvenile court to adult court.

Citing the Supreme Court’s Smith decision, the First District in 2022 vacated the tampering charge because it was not first presented in juvenile court.

The prosecutor appealed the decision to the Supreme Court, which originally held Williams’ appeal until it decided Burns. After ruling on Burns, the Court agreed to hear Williams’ case.

Supreme Court Analyzed Transfer Law 
When Williams was charged with the crime, R.C. 2151.23(H) directed juvenile courts to transfer “the case” to adult court once the juvenile court found probable cause on any charge. Once the case was transferred, Justice Fischer explained, the adult court could accept a plea or convict the juvenile for the same offense, a lesser offense, or “another offense that is different from the offense charged.”

Under the Smith decision, the adult court could move forward with charges for which the juvenile court found probable cause but not for charges in which the juvenile court found no probable cause. Soon after, the Court was asked in Burns to determine if a juvenile could be indicted in adult court for acts that were not charged in juvenile court. The Burns decision clarified the Smith decision by stating that a charge not raised in juvenile court could be presented and tried in adult court if the charge was rooted in the acts included in the juvenile complaint.

Williams argued to the Supreme Court that only charges with explicit findings in juvenile court of probable cause may be tried in adult court and that Burns was wrongly decided.

Today, the Court reaffirmed Burns and wrote that its precedent led it to conclude that Williams could face the added charge for tampering with evidence. The opinion was based on stare decisis, a legal doctrine that compels a court to recognize and follow an established legal decision in later cases. The Court noted that courts rely more on precedent when interpreting statutes because once the legislature learns of a Supreme Court decision, it can amend the law if it disagrees. And Williams did not present a compelling reason to overturn Burns, the opinion noted.

The Court, reviewing R.C. 2151.23(H), stated, “An adult court is plainly not restricted to considering only the offenses for which the juvenile court found probable cause.”

Williams’ original juvenile charges related to shooting Lawson and did not mention the sale of the gun days after. But the evidence presented at the juvenile probable cause hearing supports a finding that the murder and tampering with evidence acts were connected because it showed Williams tried to avoid being charged with murder by getting rid of the weapon, the Court stated.

Because the tampering charge “arose from the murder that was the basis of the juvenile complaint,” Williams was appropriately charged with the crime in adult court, the opinion stated. The Court remanded the case to the First District to address other claims Williams raised in his appeal.

Court Wrongly Limited Transferred Cases, Concurrence Maintained
In her concurring opinion, Chief Justice Kennedy wrote that the version of R.C. 2151.23(H) in effect at the time of Williams’ crimes granted jurisdiction to an adult court once the case was transferred from juvenile court, and the adult court could consider any charges “as if the case originally had been commenced in that court.”

“Neither of the jurisdictional limitations from Smith and Burns can reasonably be drawn from the plain language of the bindover statutes,” she wrote.

Those decisions distort the law, and stare decisis is not an obstacle to correcting the erroneous holdings of those cases, the concurrence stated, because when a court adheres to an act of statutory misinterpretation by applying stare decisis, the court perpetuates a usurpation of the legislative power. While she would not rely on Smith and Burns, the chief justice concluded that the Court reached the correct result by deciding that Williams could be indicted and convicted for tampering with evidence even if that offense was not alleged in juvenile court.

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