## Facts

- A 13-year-old boy accompanied a friend into a pet store.
- The friend proposed putting super glue on a gerbil; when asked, the boy indicated it did not matter to him.
- The friend applied super glue to the gerbil’s back; a store employee discovered it and contacted law enforcement.
- A juvenile delinquency complaint was filed alleging criminal mischief based on the pet-store incident.
- The adjudicatory hearing was initially scheduled about two months after the complaint and was then continued twice, including for witness unavailability, before proceeding several months later.
- The juvenile court adjudicated the boy delinquent, and he appealed.

## Issues

1. Whether the continuances and hearing date violated Ohio Juv.R. 29(A)’s requirement that an adjudicatory hearing be held “at the earliest practicable time” for a juvenile not in detention.
2. Whether the delay violated the juvenile’s constitutional right to a speedy trial, including whether the juvenile showed prejudice from the delay.
3. Whether the evidence was sufficient to support delinquency for criminal mischief based on the juvenile’s participation or complicity in the conduct.

## Decision

- The court of appeals affirmed the delinquency adjudication.
- The continuances did not violate Juv.R. 29(A) because they were supported by good cause and the matter proceeded as soon as practicable.
- The delay did not violate the constitutional speedy-trial right because the juvenile did not show actual prejudice.
- The evidence supported the delinquency adjudication.

## Legal Principles

- Juv.R. 29(A) requires an adjudicatory hearing to be held as soon as practicable; the rule permits continuances for good cause, including witness unavailability.
- Juvenile speedy-trial claims are evaluated under constitutional speedy-trial factors (length of delay, reason for delay, assertion of the right, and prejudice).
- Absent a showing that delay impaired the defense or caused concrete harm, a delinquency adjudication will not be reversed solely due to passage of time where delays were justified.
- Juvenile courts have discretion in scheduling adjudicatory hearings when acting within the “as soon as practicable” standard and supported by good cause.

## Conclusion

The appellate court upheld the delinquency adjudication, holding that good-cause continuances satisfied Juv.R. 29(A) and that the juvenile’s speedy-trial challenge failed because he did not show prejudice from the delay.


In re Corcoran, 68 Ohio App. 3d 213, 587 N.E.2d 957 (Ohio Ct. App. 1990)