Background
Jordan Worthey-Sturdivant, age 19, was in the custody of the Ohio Department of Youth Services (DYS) at the Indian River Juvenile Correctional Facility when he, along with co-defendants Carreyon Dukes and Demonte Williams, committed a felonious assault against another inmate. Sturdivant was indicted on one count of felonious assault, a second-degree felony, in the Stark County Court of Common Pleas. He filed a motion to remand the case to juvenile court, arguing that because he was in DYS custody at the time, the charges should have originated there.
The trial court denied the motion prior to voir dire, and the case proceeded to a jury trial. Trooper Jason Halstead of the Ohio State Highway Patrol testified about the investigation, and surveillance video from inside the facility was presented. The jury convicted Sturdivant, and the court sentenced him accordingly.
The Court’s Holding
The Fifth District affirmed, holding that the common pleas court had proper jurisdiction over Sturdivant. The court analyzed Ohio’s statutory framework governing juvenile and adult jurisdiction. Because Sturdivant was 19 years old at the time of the offense, he was an adult under Ohio law, and the fact that he happened to be in DYS custody did not confer juvenile court jurisdiction. The juvenile court’s jurisdiction over a person terminates when that person reaches the age of majority, even if they remain in DYS custody for a prior juvenile adjudication.
The court further found sufficient evidence supported the conviction. Surveillance footage and trooper testimony established that Sturdivant participated in the group assault on the victim, who sustained serious physical harm requiring medical treatment. The court also rejected a manifest weight challenge, noting the jury was free to credit the testimony and video evidence presented by the State.
Key Takeaways
- An individual over 18 who commits a new offense while in DYS custody is properly charged in adult court; the juvenile court’s jurisdiction does not extend to new criminal acts committed after the age of majority.
- DYS custody does not create a jurisdictional shield for adult-age inmates who commit crimes within juvenile correctional facilities.
- The Ohio State Highway Patrol’s Office of Investigative Services handles criminal investigations within DYS facilities.
Why It Matters
This decision resolves a question that may arise more frequently as DYS facilities house individuals who remain in custody past their 18th birthday under extended commitments. Defense attorneys should note that the mere fact of DYS custody does not create juvenile court jurisdiction over new crimes committed by individuals who are legally adults. The decision also highlights the evidentiary role of institutional surveillance footage in prosecutions arising from correctional facility incidents.