Ohio Supreme Court · 2012

In re C.P.

2012-Ohio-1446, 967 N.E.2d 729 (Ohio 2012)

Holding

Held that automatic, mandatory, lifetime sex-offender registration and notification imposed on juveniles adjudicated within the juvenile system (R.C. 2152.86) violates the Eighth Amendment prohibition on cruel and unusual punishment and the due-process requirement of fundamental fairness: for a juvenile, lifetime registration attaches its stigma at the start of adult life while character is still forming — hampering education, relationships, and work before adulthood begins — and the automatic classification eliminates the juvenile judge's discretion that the rehabilitative juvenile system requires. Applies the Roper/Graham juvenile-difference reasoning to registration consequences.

Precedent health-check

Caution · 141 citing

Some later courts have distinguished or questioned it — read before relying.

Treatment last confirmed July 18, 2026. Case-wide subsequent treatment; human-set. Not specific to any one passage.

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Claims relevant to this case

Juveniles adjudicated for sexual offenses sexually reoffend at low rates — pooled official rates of roughly 3–10% over about five years, indistinguishable from the sexual-offense rates of other delinquent youth — while their general (nonsexual) reoffending is several times higher, and individual prediction of juvenile sexual recidivism has only modest accuracy.
Evidence: HighConsensus: Established Certified· juvenile offending / recidivism