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In re A.H.

2026-08-26

Summary

Holding. The appellate court affirmed the juvenile court's adjudication finding A.H. delinquent by reason of two counts of rape and one count of gross sexual imposition, holding that the evidence, particularly the victim's detailed forensic interview, was not against the manifest weight of the evidence.

A thirteen-year-old child (A.H.) was adjudicated delinquent for two counts of rape and one count of gross sexual imposition against her six-year-old half-sister (Jane Doe). A.H. challenged the adjudication on appeal, arguing the evidence lacked credibility. She contended that the victim's normal physical examination undermined the allegations, that the forensic interviewer failed to establish the victim's ability to distinguish truth from falsehood, and that her own interview with a detective was unduly coercive. The trial court found A.H. delinquent after hearing testimony at an adjudication hearing, and imposed community control with sex offender registration rather than incarceration.

On manifest weight of the evidence review, the appellate court found the victim's forensic interview sufficiently detailed and graphic to support the conviction standing alone. The victim, though only six years old, described specific acts including digital penetration and oral contact in a manner far exceeding what would be expected from a child of her age with fabricated claims. The court noted the victim's demonstration of the touching, her statements about sensation, and her account of what the defendant told her before and after disclosure all supported the adjudication. The court rejected the argument that the absence of physical findings contradicted the evidence, as the alleged conduct would not necessarily produce detectable physical injury.

Summary generated by law.co from the public-domain opinion. The opinion text itself is public domain.

Key issues

  • Whether delinquency adjudication was supported by manifest weight of the evidence
  • Credibility and specificity of victim's forensic interview testimony
  • Significance of normal physical examination in sexual abuse cases involving young children
  • Adequacy of forensic interview methodology regarding victim's truth-telling capacity

Procedural posture

A.H. appealed the juvenile court's October 2025 delinquency adjudication to the Fifth District Court of Appeals on a single assignment of error challenging the manifest weight of the evidence.

Authorities cited

Opinion

majority opinion

[Cite as In re A.H., 2026-Ohio-3334.]

IN THE OHIO COURT OF APPEALS

FIFTH APPELLATE DISTRICT

DELAWARE COUNTY, OHIO

IN RE A.H. Case No. 25 CAF 10 0096

Opinion and Judgment Entry

Appeal from the Court of Common Pleas,

Juvenile Division, Case No. 24-08-1671-DL

Judgment: Affirmed

Date of Judgment Entry: August 26, 2026

BEFORE: Andrew J. King; Robert G. Montgomery; Kevin W. Popham, Judges

APPEARANCES: WILLIAM T. CRAMER, for Plaintiff-Appellant; MELISSA

SCHIFFEL, KATHERYN L. MUNGER, for Defendant-Appellee.

King, P.J.

{¶ 1} A.H., a delinquent child, appeals the October 16, 2025 judgment of

delinquency of the Delaware County Court of Common Pleas Juvenile Division. PlaintiffAppellee is the State of Ohio. We affirm the trial court.

Facts and Procedural History

{¶ 2} A.H. and the victim, Jane Doe, are half-sisters. Father and his fiancée A.B.

have two children in common, including Doe. Father also has two children from a prior

relationship including A.H. In 2024, A.H. and her sibling stayed with father and A.B. 50% of

the time. A.H. was thirteen years old and Doe was six. A.H. and Doe got along well.

{¶ 3} The family lived in a two-bedroom apartment with one bathroom. The girls

occasionally showered together, but in summer of 2024 A.B. noticed that behavior had become more frequent. On July 28, 2024, the family returned home from an outing. A.H. and

Doe had been arguing, which was not typical. A.B. directed the girls to shower and get ready

for bed. She directed the A.H. to shower first, but Doe got in first instead. A.H. joined her.

A.B. heard the girls in the shower and thought it was odd since they had just been arguing.

{¶ 4} Once the girls were out of the shower, A.B. asked Doe if anything inappropriate

was going on. Doe told A.B. that A.H. was touching her private parts, but had told her not to

tell. Doe demonstrated with her hand as to how A.H. had touched her private parts. A.B. and

father confronted A.H. who at first, denied the allegation, and then admitted.

{¶ 5} A.B. and father contacted law enforcement and were directed to take Doe to

Nationwide Children's Hospital for a forensic interview. Doe was seen by forensic interviewer

Hope Williams. Doe explained what happened in graphic detail. Doe then had a physical

exam with Dr. Tscholl. The exam was normal.

{¶ 6} Father took A.H to the Delaware City Police Department. Detective Madden

interviewed A.H. Detective Madden advised A.H. of the allegations against her and A.H.

agreed that Doe had alleged those things. A.H.'s mother showed up near the end of the

interview after which A.H. denied anything had happened.

{¶ 7} On August 21, 2024, Detective Madden filed two complaints in the Delaware

County Juvenile Court, the first alleging A.H. was delinquent by reason of rape of a child

under the age of 10, and the second alleging A.H. was delinquent by reason of gross sexual

imposition involving a child under the age of 10. In November 2024, Madden filed amended

complaints charging an additional count of rape and modifying the alleged dates. In February

2025, the rape counts were amended to modify the alleged dates.

{¶ 8} A.H. denied the allegations and in December 2024 moved for a competency

evaluation. In January, 2025, A.H. was found competent.

{¶ 9} On April 3 and 16, 2025, an adjudication hearing took place wherein the above

outlined facts were presented by the State. A.H. testified on her own behalf. She testified that

she had only admitted to the allegation due to pressure from father and because he threatened

she would go to the juvenile detention center if she did not admit the allegations.

{¶ 10} At the conclusion of testimony, the trial court took the matter under

advisement. On May 16, 2025, via judgment entry, the trial court adjudicated A.H. delinquent

by reason of two counts of rape and one count of gross sexual imposition. At a later

dispositional hearing, the trial court imposed a term of legal custody to the Department of

Youth Services for six months and up to the age of 21. The court suspended that term and

placed A.H. on community control with various conditions. A.H. was further classified as a

Tier I sex offender.

{¶ 11} A.H. filed an appeal and the matter is now before this court for consideration.

She raises one assignment of error as follows:

I

{¶ 12} "THE AJUDICATION OF DELINQUENCY WAS NOT SUPPORTED BY

THE WEIGHT OF THE EVIDENCE."

{¶ 13} In her sole assignment of error, A.H. argues her delinquency adjudication is

against the manifest weight of the evidence. We disagree.

Standard of Review

{¶ 14} A review of the sufficiency of the evidence and a review of the manifest weight

of the evidence are separate and legally distinct determinations. State v. Thompkins, 78 Ohio St.3d 380, 387(1997) "While the test for sufficiency requires a determination of whether the

State has met its burden of production at trial, a manifest weight challenges questions whether

the State has met its burden of persuasion." Id. at 390.

{¶ 15} An appellate court applies the same manifest weight standard of review in a

juvenile delinquency case that it applies in an adult criminal appeal. Matter of T.S., 2022-Ohio975, ¶ 26 (5th Dist.), citing In re E.A., 9th Dist. Summit No. 28106, 2016-Ohio-7281, ¶ 11. On

review for manifest weight, a reviewing court is to examine the entire record, weigh the

evidence and all reasonable inferences, consider the credibility of witnesses and determine

"whether in resolving conflicts in the evidence, the [finder of fact] clearly lost its way and

created such a manifest miscarriage of justice that the conviction must be reversed and a new

trial ordered." State v. Martin, 20 Ohio App.3d 172, 175 (1st Dist.1983). See also, State v.

Thompkins, 78 Ohio St.3d 380 (1997). The granting of a new trial "should be exercised only

in the exceptional case in which the evidence weighs heavily against the conviction." Martin

at 175.

A.H's Arguments

{¶ 16} A.H. was found delinquent by reason of two instances of rape and one instance

of gross sexual imposition. A.H. does not allege the state failed to produce evidence of any of

the elements of either offense. Rather, she argues the evidence produced by the State lacked

credibility.

{¶ 17} A.H first points out that Doe's physical exam was normal. However, given the

allegations of digital penetration and mouth-to-breast touching, Dr. Tscoll testified she would

not expect to find any physical evidence. Transcript of trial (T.) at 184-185. A.H. additionally

faults Hope Williams, the forensic examiner, for failing to ask Doe questions to determine whether she knew the difference between telling the truth and telling a lie. Finally, A.H.

alleges her interview with Detective Madden was unduly coercive and that Madden prevented

A.H.'s mother from seeing her.1

{¶ 18} While the trial court certainly heard this evidence, the trial court also viewed

the content of Doe's forensic interview with Hope Williams. We note that Doe described what

happened in graphic detail, far beyond the knowledge of a six-year old. She stated A.H. was

"doing things that were inappropriate," "grabbed my hand and put it in her peepee," and used

her hand to touch Doe's "peepee." Doe demonstrated how her sister moved her hand when

touching Doe's vagina by moving her pointer finger up and down. She stated it felt "ticklish

and funny." Doe reported that when her sister made her digitally penetrate her vagina in the

same manner, she told Doe she was doing "what boys do to girls," and asked Doe to "flick"

her private parts. Doe stated when she put her finger in her sister's "peepee" it was "wet and

gooey" and that when she removed her finger, there was something "white" on it which she

removed by flicking her finger. Doe additionally said her sister made her "lick her boobies"

and "suck on it like a baby." State's exhibits A, B1-B12. Finally, Doe stated A.H. told her not

to tell or she would never play with Doe again. State's Exhibit A. When Doe did tell and after

her parents confronted A.H., A.H. "cried all the way to her room" and told Doe "that's your

fault." Id.

{¶ 19} Even without considering any other evidence, including A.H.'s interview with

Detective Madden, given its graphic and detailed nature Doe's forensic interview standing

alone established A.H.'s delinquency beyond a reasonable doubt. Indeed, the trial court's

judgment entry indicates Doe's interview "is among the most troubling, and most impactful

1 We note A.H did not file a motion to suppress.

child victim interviews that the Court has seen in the more than two and a half decades of

handling juvenile delinquency matters." Judgment Entry, May 16, 2025 at 16. We agree.

Accordingly, we find this is not an exceptional case in which the evidence weighs heavily

against a conviction, and the trial court did not lose its way in finding Doe delinquent by

reason of two counts of rape and one count of gross sexual imposition.

{¶ 20} The sole assignment of error is overruled, and the judgment of the Delaware

County Court of Common Pleas is affirmed.

{¶ 21} Costs to Appellant.

By: King, P. J.

Montgomery, J. and

Popham, J. concur.