In re P.M.S.

Summary

The Supreme Court of Ohio affirmed the Twelfth District Court of Appeals’ judgment upholding a juvenile delinquency adjudication for rape under R.C. 2907.02(A)(2). The court held that sufficient evidence supported a finding that the juvenile used force, as defined by R.C. 2901.01(A)(1), to compel the victim to submit to sexual conduct, including evidence that the juvenile physically held the victim and continued despite the victim’s objections.

Holdings

1. The same sufficiency-of-the-evidence standard used to review adult criminal convictions applies to juvenile-delinquency adjudications, and the sufficiency question is reviewed de novo.
2. Force under R.C. 2907.02(A)(2) includes violence, compulsion, or constraint physically exerted by any means; only minimal force is necessary to support a rape conviction.
3. The evidence was sufficient for a rational trier of fact to find beyond a reasonable doubt that P.M.S. used force to compel the victim to submit to sexual conduct.

Questions Presented

1. Whether the evidence was sufficient to prove the force element of rape under R.C. 2907.02(A)(2) in a juvenile-delinquency adjudication.
2. Whether physical force inherent in the sexual act may be considered, together with other evidence of physical compulsion or constraint, in determining whether the offender compelled the victim to submit by force.

Disposition

affirmed