Ohio v. Quarterman
On March 10, 2014, NJDC with Juvenile Law Center, and the Ohio Chapter of the American Academy of Pediatrics filed an amicus brief arguing that Ohio’s mandatory bindover statutes are unconstitutional under the due process clause of the Fourteenth Amendment because they do not allow for individualized determinations regarding the appropriateness of prosecuting certain minors in adult criminal court rather than juvenile court.
The underlying case was brought on behalf of Alexander Quarterman, who was 16 at the time of his offense where he allegedly use of a firearm to commit a robbery. Because of his age he was subjected to mandatory transfer to adult court pursuant to Ohio statute. If Alexander had been 15 at the time of his offense, he would have been subject only to discretionary transfer after the juvenile court conducted an amenability hearing and found he was not amenable to rehabilitation. However because of his age, Ohio’s mandatory transfer scheme prohibited the juvenile court from considering mitigating factors of youth before transferring him to adult court.
Amici assert that because the statute deprives youth of individualized determination of amenability, it violates general due process principles, the U.S. Supreme Court’s holding in Kent that youth are entitled to strong due process protections when their case is transferred from juvenile to adult court, and the Supreme Court’s precedents recognizing that juveniles possess unique characteristics that make adult sentences often inappropriate.
Court: Supreme Court of Ohio
Filed: March 10, 2014 (download .pdf)
Amicus Brief Discusses: Due Process Clause; Transfer
Oral Argument: July 8, 2014