State v. Zarlengo

New Decision

Following a probable cause hearing in juvenile court, Manny Zarlengo was automatically transferred to adult court for his alleged involvement in several robberies at age 16. Faced with a prison sentence of up to 136 years, Manny pled guilty and received a sentence of 18 years. On appeal, Manny sought to challenge the juvenile court’s probable cause determination. An Ohio Court of Appeals held that, because Manny pled guilty in adult court, he waived his right to challenge the juvenile court’s initial probable cause determination.

Juvenile Law Center, the Gault Center, and the Rutgers Criminal and Youth Justice Clinic filed an amicus brief in the Ohio Supreme Court in support of Manny, arguing that because adolescents are uniquely vulnerable when plea bargaining, their decisions should not waive their ability to challenge the underlying transfer. We emphasized scientific research that shows adolescents have deficiencies in their capacity for decision-making as well as diminished legal capacity, which puts them at risk of making poor plea decisions. We further argued that limiting the right to appeal an underlying probable cause determination will disproportionately impact Black youth, who are more likely to be transferred to the adult criminal system.

In January 2023, Manny requested voluntary dismissal and the Ohio Supreme Court dismissed the appeal. 



Andrew Keats, Marsha Levick, Riya Saha Shah


Tiffany Faith, Marissa Lariviere