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← 114 Ohio App. 3d 290 - In Re Hendrickson

114 Ohio App. 3d 290 - In Re Hendrickson’s Empirical Analysis

1996

Citation profile

23
cited by 23 later decisions
1
states following
August 2025
most recently cited

23 state decisions

How this case has been cited

Cited by 23 later decisions — most recently August 2025

23 state decisions

1001996200020102020decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

Relationships

Relies on 101 Ohio App. 3d 245 - In Re Christopher R. · 57 Ohio St. 2d 31 - State v. Billups · 101 Ohio App. 3d 778 - In Re Flynn · 102 Ohio App. 3d 275 - In Re McKenzie · 101 Ohio App. 3d 177 - In Re Jenkins

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 23 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “{¶ 39} “The critical issue, then, is whether Judge Monnin’s colloquy demonstrates substantial compliance with the requirements of Juv.R. 29(D). Based upon our review of the hearing transcript, we conclude that it does not. In particular, we find troubling the judge’s failure to provide Hendrickson with any information concerning the possible sentence the court could impose. We recognize that, unlike Crim.R. 11(C)(2), Juv.R. 29(D) does not expressly require the court to inform a juvenile of the maximum penalty he faces. Nevertheless, Juv.R. 29(D) does require the court to convey the ‘consequences’ of the juvenile’s admission. {¶ 40} “Neither party cites, nor can this court locate, any cases construing the term ‘consequences’ as used in Juv.R. 29(D). In our view, however, the potential for commitment to the Ohio Department of Youth Services for a period of one to six years is a significant consequence that the judge should have mentioned to Hendrickson. Indeed, in the eyes of a fifteen-year-old * * *, the possibility of a lengthy commitment well may be the most important consequence imaginable. Consequently, we hold that Juv.R. 29(D)(1) and the rudiments of due process required the trial court to apprise Hendrickson, at least briefly, of its dispositional options.””
    1 later decision quote this exact passage
  2. “failure of the juvenile court to substantially comply with Juv.R. 29(D) has [a] * * * prejudicial effect * * * necessitating a reversal of the adjudication so that the juvenile may plead anew.”
    1 later decision quote this exact passage
  3. “(1) The party is making the admission voluntarily with understanding of the nature of the allegations and the consequences of the admission; {¶ 58}”
    1 later decision quote this exact passage

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.