State v. Carnes

Anthony Carnes was adjudicated delinquent without the benefit of attorney representation when he was a youth. Nearly 20 years later he was sentenced to two and half years in prison for conduct that was only deemed criminal because of his previous childhood adjudication.

Juvenile Law Center and National Juvenile Defender Center, along with pro bono counsel Winston & Strawn LLP, filed an amicus brief in the Ohio Supreme Court in support of Mr. Carnes. We argued that juvenile adjudications are insufficient "to alone sustain proof beyond a reasonable doubt of an element of [an adult felony]" because it contradicts the rehabilitative purpose of Ohio's juvenile justice system.

The Ohio Supreme Court held that using a prior juvenile adjudication as an element of an adult offense under Ohio’s weapons-under-disability statute does not violate due process or undermine the rehabilitative purpose of the juvenile justice system.