State ex rel. Wade v. Shoop

Summary

The Supreme Court of Ohio affirmed dismissal of Jordyn Wade’s habeas corpus petition challenging the jurisdiction of the adult court that convicted him. The court held that the juvenile-to-adult bindover satisfied statutory procedural requirements and that the adult court therefore did not patently and unambiguously lack subject-matter jurisdiction. Applying State v. Turner, the court further held that the adult court’s jurisdiction extended to the offenses charged in the indictment, including aggravated murder and murder counts not specifically charged or supported by a probable-cause finding in juvenile court.

Holdings

1. Wade's alleged intellectual disability and claimed mental age did not establish a patent and unambiguous lack of subject-matter jurisdiction because he was 16 at the time of the offenses, satisfied the statutory minimum-age requirement for mandatory bindover, and the bindover statutes did not require a separate determination of effective mental capacity.
2. Once the juvenile court transferred Wade's case to adult court, the adult court had subject-matter jurisdiction over the entire case and over any offense for which the grand jury returned an indictment, including aggravated murder and other offenses not specifically charged or supported by a separate juvenile-court probable-cause finding.
3. The petition failed to state a claim for habeas corpus relief because Wade did not plead facts showing that the adult court patently and unambiguously lacked subject-matter jurisdiction, and the Fourth District properly dismissed the petition.

Questions Presented

1. Whether Wade's alleged intellectual disability or mental capacity equivalent to that of an 11- or 12-year-old established that the adult court patently and unambiguously lacked subject-matter jurisdiction over his case.
2. Whether the adult court lacked subject-matter jurisdiction to convict Wade of aggravated murder, additional murder counts, and other offenses because the juvenile court had not charged those offenses or specifically found probable cause for them before transferring the case.
3. Whether Wade stated a cognizable claim for habeas corpus relief when he had an adequate remedy in the ordinary course of law through trial and direct appeal.

Disposition

affirmed