In re J.L.

[Cite as In re J.L., 2026-Ohio-4265.] STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF SUMMIT ) IN RE: J.L. C.A. No. 31804 APPEAL FROM JUDGMENT ENTERED IN THE COURT OF COMMON PLEAS COUNTY OF SUMMIT, OHIO CASE No. DL 25-06-0612 DECISION AND JOURNAL ENTRY Dated: October 28, 2026 STEVENSON, Judge. {¶1} Defendant-Appellant, J.L, a juvenile, appeals the judgment of the Summit County Juvenile Court finding him delinquent on one count of aggravated robbery and one count of felonious assault, with two firearm specifications on each count, and sentencing him on these offenses. We affirm in part, reverse in part, and remand for further proceedings consistent with this decision. I. {¶2} This matter arises from an armed robbery that occurred at a park in Akron, Ohio, on June 18, 2025. J.L. and his friends arrived at the park with Ih.J and his younger brother Ib.J. J.L. pulled out a gun and ordered Ih.J. to hand over his cell phone. Ih.J tried to grab the gun from J.L. and in the ensuing tussle over the cell phone, J.L. discharged the gun and shot Ih.J. in the abdomen. J.L. fled the scene with his friends. Ih.J. and Ib.J. picked up the gun, ran home, and  2 threw the gun into their front yard. Ih.J. called 911 and eventually went to the hospital. The police recovered the gun from the yard. {¶3} J.L. was charged with one count of aggravated robbery in violation of R.C. 2911.01(A)(1), a felony of the first degree, and one count of felonious assault in violation of R.C. 2903.11(A)(2), a felony of the first degree, later amended to a felony of the second degree. Both charges included two firearm specifications. Following an adjudicatory hearing on December 16, 2025, the trial court found J.L. delinquent on both charges and the attendant firearm specifications. The trial court held a dispositional hearing on January 12, 2026, and orally announced its intention to commit J.L. to the Ohio Department of Youth Services (“ODYS”). In its final dispositional entry, dated January 16, 2026, the court stated: Due to the firearm specification, reasonable efforts could not be made to maintain [J.L.] in his mother’s custody as commitment to the [ODYS] is mandatory. ... [J.L.] is committed to the custody of the [ODYS], effective 01/12/2026, for a minimum term of 1 Year(s) to a maximum term to age twenty-one (21) on Count 1 2911.01 F1 AGGRAVATED ROBBERY Count 2 2903.11 F2 Felonious Assault. [J.L.] shall be committed to the [ODYS] for a mandatory period of one year on the firearm specification on Counts 1 and 2. These terms shall be served concurrently with each other and consecutively to the terms of commitment on the underlying charges. The terms of commitment on Counts 1 and 2 shall be served concurrently with each other and consecutively to the term of commitment on the firearm specification. The total minimum term of commitment is two (2) years. {¶4} J.L. timely appealed and asserts six assignments of error for our review. II. ASSIGNMENT OF ERROR 1. THE TRIAL COURT LACKED JURISDICTION TO ISSUE A DISPOSITIONAL SENTENCING JOURNAL ENTRY WHILE THE MATTER WAS ON APPEAL.  3 {¶5} On January 15, 2026, between the January 12, 2026, dispositional hearing and the trial court’s January 16, 2026, written judgment, J.L.’s trial counsel filed a “NOTICE OF INTENT TO APPEAL” indicating an intent to appeal the verdict and request the appointment of appellate counsel. On January 20, 2026, J.L. filed a “NOTICE OF APPEAL.” J.L. argues that based on this sequence of filings, the juvenile court issued its January 16, 2026, judgment while an appeal was pending, and therefore, the court lacked jurisdiction to proceed with an adjudication of J.L., rendering that judgment null and void. In support, J.L. cited several decisions standing for the proposition that a juvenile court lacks jurisdiction to proceed with an adjudication of a child after a notice of appeal has been filed from of an order of that court. See, e.g., In re J.B., 2007-Ohio- 246, ¶ 11 (9th Dist.); In re S.J., 2005-Ohio-3215, ¶ 9. {¶6} As this assignment of error challenges the trial court’s jurisdiction, our review is de novo. In re K.G., 2022-Ohio-3218, ¶ 12 (9th Dist.). In a de novo review, “this [C]ourt has complete and independent power of review . . . .” Grafton v. Ohio Edison Co., 77 Ohio St.3d 102, 105 (1996). {¶7} Under R.C. 2505.04, “[a]n appeal is perfected when a written notice of appeal is filed[.]” (Emphasis added.). The notice filed on January 15, 2026, was captioned “NOTICE OF INTENT TO APPEAL” and merely informed the court that J.L. intended to appeal. Therefore, it was not a proper notice of appeal under R.C. 2505.04. {¶8} Moreover, even if the “NOTICE OF INTENT TO APPEAL” could be construed as a proper notice of appeal, the trial court nonetheless had jurisdiction under App.R. 4(C) to issue its written judgment entry journalizing the dispositional sentence. App.R. 4(C) states that “[a] notice of appeal filed after the announcement of a decision, order, or sentence but before entry of the judgment or order that begins the running of the appeal time period is treated as filed  4 immediately after the entry.” In this case, the juvenile court orally imposed sentence at the January 12, 2026, hearing. Thus, assuming the “NOTICE OF INTENT TO APPEAL” was a proper notice of appeal, under App.R. 4(C) the notice was deemed as filed after the trial court’s written January 16, 2026, dispositional entry and the trial court had jurisdiction to enter its written judgment. See, e.g., State v. Williamson, 2016-Ohio-5731, ¶ 5 (2d Dist.) (App.R. 4(C) applied where the notice of appeal was filed after announcement of sentence in open court but before its journalization). {¶9} Accordingly, based on the foregoing, the trial court was vested with jurisdiction to issue its January 16, 2026, sentencing entry. J.L.’s first assignment of error is overruled. ASSIGNMENT OF ERROR 2. THE JUVENILE FAILED TO RECEIVE EFFECTIVE ASSISTANCE OF COUNSEL WHEN HIS TRIAL ATTORNEY DID NOT TIMELY OBJECT TO DEFECTS IN THE COMPLAINT PRIOR TO THE ADJUDICATORY HEARING. {¶10} J.L. states that the complaints in his case contained numerous defects. The complaints were signed by Akron Police Officer Kelly Brown and sworn by a “Trained Law Enforcement Officer.” J.L. acknowledges that R.C. 2935.081(B) permits “[a] peace officer who has completed a course of in-service training that includes training in the administration of oaths and the acknowledgment of documents and that is approved by the chief legal officer of the [officer’s] political subdivision” to administer oaths and acknowledge juvenile complaints. However, he argues that no evidence was ever presented in his case regarding the “Trained Law Enforcement Officer[’s]” qualifications. J.L. further argues that because Juv.R. 10(B)(3) specifically requires that any person who files a complaint alleging that a child is a delinquent child must file it “under oath[,]” a juvenile complaint not properly made “under oath” is defective. See In re Dukes, 81 Ohio App.3d 145, 150 (9th Dist. 1991).  5 {¶11} J.L. further states that the complaint is defective because R.C. 147.542(A) directs notaries to provide a notarial certificate for every notarial act they perform that meets the requirements of R.C. 147.542(F)(1)-(7). However, J.L. points out that in his case, there was no notarial certificate on the complaints nor do the complaints otherwise contain the items listed in R.C. 147.542(F)(1)-(7). J.L. maintains that those requirements are mandatory based on the use of the word “shall” in R.C. 147.542(A). State v. Senk, 2024-Ohio-6096, ¶ 15 (9th Dist.) (“‘Shall’ means must.”). {¶12} Last, J.L. points out that both complaints have a checkbox next to the two types of firearm specifications but there are no numerical designations of the statute or ordinance alleged to have been violated by J.L. J.L. contends that Juv.R. 10(B)(1) specifically provides that the complaint “shall contain the numerical designation of the statute or ordinance alleged to have been violated[.]” {¶13} J.L. argues on appeal that his trial counsel was ineffective for failing to challenge the above defects in the complaint by filing a pretrial motion to dismiss under Juv.R. 22(D)(2) (Defenses or objections based on defects in the complaint). To prevail on a claim of ineffective assistance of counsel, J.L. must establish: (1) his counsel's performance was deficient to the extent that “counsel was not functioning as the ‘counsel’ guaranteed the defendant by the Sixth Amendment” and (2) counsel's deficient performance prejudiced the defense. Strickland v. Washington, 466 U.S. 668, 687 (1984). A deficient performance is one that “fall[s] below an objective standard of reasonable representation . . . .” State v. Bradley, 42 Ohio St.3d 136 (1989), paragraph two of the syllabus. “[I]n Ohio, a properly licensed attorney is presumed competent.” State v. Gondor, 2006-Ohio-6679, ¶ 62. In addition, to establish prejudice, J.L. must show that there existed “a reasonable probability that, but for counsel's unprofessional errors, the result of  6 the proceeding would have been different.” Strickland at 694; State v. Sowell, 2016-Ohio-8025, ¶ 138. Both prongs under Strickland must be established to support an ineffective assistance of counsel claim. Strickland at 687. “An error by counsel, even if professionally unreasonable, does not warrant setting aside the judgment of a criminal proceeding if the error had no effect on the judgment.” Id. at 691. As the Supreme Court of Ohio has previously stated, “debatable trial tactics do not establish ineffective assistance of counsel.” State v. Leonard, 2004-Ohio-6235, ¶ 146. We review claims of ineffective assistance of counsel on a de novo basis. State v. Porter, 2013-Ohio- 3969, ¶ 37 (9th Dist.), citing Gondor at ¶ 53. {¶14} J.L. argues that his trial attorney’s performance was deficient and below any objective standard of reasonable representation for not challenging the defects in the complaints, and that there was more than a reasonable probability that a motion to dismiss would have been granted, thus preventing him from being found delinquent. He further argues that trial counsel’s failure prejudiced him, resulting in a “fundamentally unfair outcome” and that there was no strategic basis for trial counsel’s failure. He asks this Court to reverse and remand the matter to the trial court and order it to dismiss the complaints. {¶15} We disagree with J.L. that his counsel’s actions were deficient in the first instance. First, to the extent that J.L. is arguing that the officer who signed the complaints was not actually a “Trained Law Enforcement Officer” under R.C. 2935.081(B), he is relying on evidence outside the record, which is not properly the subject of an ineffective assistance claim. State v. Biggins, 2018-Ohio-1878, ¶ 10 (9th Dist.); State v. Zupancic, 2013-Ohio-3072, ¶ 4 (9th Dist.). Second, there is no support for J.L.’s argument that the complaints must comply with R.C. 147.542(F)’s formal requirements for notarized documents. Juv.R. 10(B)(3) only requires that the complaint “[b]e made under oath.” R.C. 2152.021(A)(2) similarly requires only that “[a]ny person having  7 knowledge” of a potentially delinquent child “may file a sworn complaint with respect to that child[.]” Neither Juv.R. 10(B)(3) nor R.C. 2152.021(A)(2) state that a notarized document in accordance with R.C. 147.542(F) is required nor has J.L. cited to any case law holding that R.C. 147.542(F) applies to delinquency complaints and “Trained Law Enforcement Officers.” Thus, any such claim by trial counsel that R.C. 147.542(F) applies in this case would have been a novel argument. Trial counsel’s performance is not deficient under Strickland if he fails to present a novel argument. State v. McNeill, 83 Ohio St.3d 438, 449 (1998) (not ineffective assistance to “declin[e] to present untested or rejected legal theories”). Moreover, adherence to R.C. 147.542(F)’s list of technical formalities would be inconsistent with precedent from this Court rejecting such requirements for an indictment or complaint. Matter of Foster, 1998 WL 240113, *2 (9th Dist. May 13, 1998) (“[a] delinquency complaint need not conform to a ‘hypertechnical’ requirement not required by the function and purpose of a delinquency complaint”). {¶16} Turning to J.L.’s last claim regarding the lack of explicit reference to an Ohio Revised Code section, it is likewise without merit as this Court has already rejected that argument. In re G.E.S., 2008-Ohio-2671, ¶ 15 (9th Dist.), citing Foster at *3. (“[A] complaint in a juvenile delinquency proceeding need not specify the exact numerical designation of the statutory subsection under which the State intends to proceed so long as a reasonable, ordinary person would understand the charges against him, based on the language in the complaint.”). Here, the language of the complaints contained the applicable statutory language of R.C. 2941.141(A) and R.C. 2941.145(A), respectively, for both firearm specifications: [] [t]he offender had a firearm on or about the offender’s person or under the offender’s control while committing the offense. [] [t]he offender had a firearm on or about the offender’s person or under the person’s control while committing the offense and displayed the firearm,  8 brandished the firearm, indicated that the offender possessed the firearm, or used it to facilitate the offense. Thus, although the complaints did not contain the specific numerical designation of the statutory section, “a reasonable, ordinary person would understand the charges against him, based on the language in the complaint” because it matched the statutory language. In re G.E.S. at ¶ 15. {¶17} As the complaints did not contain defects that trial counsel could have reasonably challenged, trial counsel’s actions in not challenging the complaints did not constitute deficient performance. Since both prongs of Strickland must be satisfied to establish ineffective assistance, J.L. cannot support his claims here. His second assignment of error is overruled. ASSIGNMENT OF ERROR 5. THE JUVENILE FAILED TO RECEIVE EFFECTIVE ASSISTANCE OF COUNSEL WHEN HIS TRIAL ATTORNEY DID NOT ARGUE AT HIS SENTENCING DISPOSITIONAL HEARING THAT HIS TWO FELONIES SHOULD HAVE BEEN MERGED AS THEY WERE ALLIED OFFENSES. {¶18} R.C. 2941.25(B) provides that [w]here the defendant’s conduct constitutes two or more offenses of dissimilar import, or where his conduct results in two or more offenses of the same or similar kind committed separately or with a separate animus as to each, the indictment or information may contain counts for all such offenses, and the defendant may be convicted of all of them. {¶19} “[W]hen determining whether offenses are allied offenses of similar import within the meaning of R.C. 2941.25, courts must ask three questions when defendant’s conduct supports multiple offenses: (1) Were the offenses dissimilar in import or significance? (2) Were they committed separately? and (3) Were they committed with separate animus or motivation?” State v. Earley, 2015-Ohio-4615, ¶ 12, quoting State v. Ruff, 2015-Ohio-995, ¶ 31. {¶20} Here, J.L. argues that trial counsel should have made the argument that his two felonies were allied offenses of similar import and that he should have been sentenced on just one of them. He maintains that the evidence at trial showed there was only one act involving only one  9 victim who received only one harm, and that the two acts of aggravated robbery and felonious assault occurred simultaneously and with the same purpose, intent and motive. We disagree. {¶21} We reiterate the standard set forth above for establishing ineffective assistance of counsel. J.L. argues that there was no strategic basis for his trial counsel’s failure to advance a merger argument, and as such, his trial counsel’s performance was deficient. He further argues that he was prejudiced by this failure because there was more than a reasonable probability that if his counsel had timely raised the claim, it would have prevented him from being sentenced on two felonies under Ohio law. See State v. Williams, 2016-Ohio-7658, ¶ 28 (“[W]hen a trial court concludes that an accused has in fact been found guilty of allied offenses of similar import, it cannot impose a separate sentence for each offense.”). He asks this Court to reverse his sentence and remand back to the trial court for further proceedings. “[A] defendant's conduct that constitutes two or more offenses against a single victim can support multiple convictions if the harm that results from each offense is separate and identifiable harm from the harm of the other offense.” State v. Ruff, 2015-Ohio-995, ¶ 26. {¶22} Other appellate courts have recognized that even when the two offenses of aggravated robbery and felonious assault occur within the same incident such as in J.L.’s case, they may have a separate animus and cause separate harms. See, e.g., State v. Gambino, 2022- Ohio-1554, ¶ 49 (11th Dist.) (court found separate harms for the purposes of merger of felonious assault and aggravated robbery where a defendant caused harm by physical injury as well as deprivation of property); State v. Ison, 2025-Ohio-3193, ¶ 43 (11th Dist.) (after knocking the victim to the ground, the defendant committed the separate harm of stealing the victim’s money); State v. Frierson, 2024-Ohio-5521, ¶ 29, 31 (6th Dist.) (aggravated robbery caused harm to the victim’s property (theft of vehicle) and serious physical harm to the victim; thus “the aggravated  10 robbery resulted in harm that was ‘separate and identifiable’ from the harm caused by the felonious assault.”); State v. Guevara, 2023-Ohio-1448, ¶ 25 (10th Dist.) (finding separate harms, i.e., physical injury and the deprivation of personal property where the defendant beat the victim severely then drove away in the victim’s vehicle); State v. Gillespie, 2021-Ohio-3650, ¶ 47 (12th Dist.) (the aggravated robbery resulted in the victim being deprived of cash, while the felonious assault resulted in the victim’s severe injuries). {¶23} Therefore, based on the plethora of case law supporting the proposition that felonious assault and aggravated robbery are not necessarily allied offenses of similar import, trial counsel’s decision not to raise the issue of merger does not constitute deficient performance. Furthermore, under the facts and circumstances of J.L.’s case, his conduct created separate, identifiable harms stemming from separate conduct. First, J.L. pulled a gun on Ih.J., and ordered Ih.J to give him his phone. Afterwards, J.L. engaged in a separate act during which he and Ih.J tussled, then J.L. shot the gun, resulting in serious injury to Ih.J. Thus, two distinct harms occurred from two separate acts. See, e.g., State v. Hathorn, 2023-Ohio-3936, ¶ 38 (3d Dist.) (actions were separate and distinct where defendant was convicted of felonious assault for shooting the victim and aggravated robbery for attempting to remove the victim’s firearm). {¶24} As J.L. did not establish that his counsel’s performance was deficient under Strickland, his fifth assignment of error is overruled. ASSIGNMENT OF ERROR 3. THE TRIAL COURT COMMITTED REVERSIBLE AND PLAIN ERROR WHEN IT IMPOSED A MANDATORY PERIOD OF INCARCERATION FOR AN UNSPECIFIED FIREARM SPECIFICATION. {¶25} At the conclusion of the December 16, 2025, adjudicatory hearing, the court stated “I’m going to find [J.L.] delinquent of one count of aggravated robbery with the firearm  11 specification and, likewise, find him delinquent on one count of felonious assault, again, with the firearm specification.” The Court’s December 17, 2025, adjudicatory order likewise stated: Based on the testimony and evidence the Court finds, beyond a reasonable doubt, that [J.L.] is a delinquent child on one count of Aggravated Robbery (F1) with both firearm specification[s] as set forth in the complaint and one count of Felonious Assault (F2) with the firearm specifications set forth in the complaint. {¶26} J.L. complains that while the court stated at the conclusion of the adjudicatory hearing that it found him delinquent of both offenses with “the” firearm specification attached to each felony, its December 17, 2025, adjudicatory order stated that it found him delinquent of “both” firearm specifications for each count without listing which specific firearm specification J.L. was to have violated, and as a result, it was vague and unknown which firearm statute he was found to have violated. {¶27} J.L. makes a similar argument regarding the court’s January 16, 2026, dispositional judgment entry. He argues that while the trial court held that counts one and two were to be run concurrently with each other and consecutively to the firearm specifications, the court did not specify which firearm statute was violated, and therefore, it was vague and unknown which firearm statute he was sentenced under. {¶28} J.L. submits that, presuming the firearm specifications are from R.C. 2941.141(A) and R.C. 2941.145(A), “[t]he difference matters a great deal because a one-year firearm specification is listed under R.C. 2941.141(A), while a three-year firearm specification is listed under R.C. 2941.145(A).” J.L. emphasizes that under R.C. 2152.17(A)(1), the trial court “may commit” the child to ODYS for up to one year for the firearm specification listed under R.C. 2941.141(A) (Emphasis added.), meaning that the term of up to one year is discretionary and not a mandatory sentence for a violation of the one-year firearm specification. However, R.C. 2152.17(A)(2) states that the trial court “shall commit” the child to ODYS for between one to three  12 years for the firearm specification under R.C. 2941.145(A) which means that the imposition of a sentence would be mandatory if J.L. was found to have committed a R.C. 2941.145(A) offense. {¶29} J.L. argues that his due process rights were violated because the trial did not provide proper notice of which specific violation it found beyond a reasonable doubt, and that if J.L. committed a R.C. 2941.141(A) violation, the trial court committed reversible error by imposing a mandatory sentence of one year when it had the discretion to keep J.L. in the community as the sentence was then discretionary. He avers that any ambiguity in the court’s ruling should be construed in his favor under R.C. 2901.04(A)’s so-called “rule of lenity” (“sections of the Revised Code defining offenses or penalties shall be strictly construed against the state, and liberally construed in favor of the accused.”) As such, J.L. asks this Court to rule that, at most, he committed a violation of R.C. 2941.141(A), which in turn means that the trial court had discretion to impose a definite period of up to one year on top of his felonies. He requests that this Court reverse and remand for the trial court to apply the proper legal standard. See, e.g., In re A.M., 2017-Ohio-7690, ¶ 8 (9th Dist.) and In re Adoption of P.L.H., 2017-Ohio-5824, ¶ 33 (application of the wrong legal standard ordinarily requires remand). {¶30} We generally review a juvenile court’s dispositional sentence in delinquency cases for an abuse of discretion. In re A.P., 2025-Ohio-219, ¶ 13 (9th Dist.). However, as J.L. is arguing that the trial court committed an error of law, the standard of review is de novo. State v. Williams, 2023-Ohio-3647, ¶ 8. {¶31} First, we have already determined under our analysis of J.L.’s second assignment of error that the complaints were not defective for failure to include the numerical designations of the statute or ordinance alleged to have been violated because the language matched the statutory language for the one-year and three-year firearm specifications under R.C. 2941.141 and R.C.  13 2941.145, and a reasonable, ordinary person would have understood the charges. As set forth above, the December 17, 2025, adjudicatory order stated that the court found J.L. delinquent on both charges, including both firearms specifications on each count. Thus, by extension, the trial court’s adjudicatory order clearly means that J.L. was found delinquent of both a one-year and a three-year firearm specification. {¶32} During the dispositional hearing, the court orally stated that “the law requires that I commit you to the Department of Youth Services. I do not have the legal option of keeping you in the community because of the firearm specification.” Consistent with that oral pronouncement, the court wrote in its dispositional entry that: Due to the firearm specification, reasonable efforts could not be made to maintain [J.L.] in his mother’s custody as commitment to the [ODYS] is mandatory. ... The Juvenile is committed to the custody of the [ODYS], effective 01/12/2026, for a minimum term of 1 Year (s) to a maximum term to age twenty-one (21) on Count 1 2911.01 F1 AGGRAVATED ROBBERY Count 2 2903.11 F2 Felonious Assault. [J.L.] shall be committed to the [ODYS] for a mandatory period of one year on the firearm specification on Counts 1 and 2. These terms shall be served concurrently with each other and consecutively to the terms of commitment on the underlying charges. (Emphasis added.) {¶33} Based on the court’s use of the term “mandatory” it is clear that J.L. was ordered to confinement at ODYS for the firearm specification under R.C. 2152.17(A)(2), which as J.L. acknowledged, provides for the imposition of a mandatory one to three-year sentence. Therefore, reading the statute together with the court’s entries and oral pronouncements there is no confusion or ambiguity that the court was sentencing J.L. under the mandatory provision. As the court would have had no obligation to impose an ODYS commitment under R.C. 2152.17(A)(1), the  14 discretionary “up to one year” provision, the court’s use of the term “mandatory” eliminates that section as being applicable to J.L.’s sentence. {¶34} In sum, the trial court’s pronouncements and judgment entries imposing a mandatory commitment to ODYS clearly indicates that the trial court ordered J.L.’s ODYS commitment under the one to three-year firearm specification. Accordingly, we cannot conclude that the trial court erred for failing to state which firearm specification J.L. violated and was sentenced under. His third assignment of error is overruled. ASSIGNMENT OF ERROR 4. THE TRIAL COURT COMMITTED REVERSIBLE AND PLAIN ERROR WHEN IT FAILED TO STATE IN THE JUVENILE’S ORDER OF COMMITMENT THE TOTAL NUMBER OF DAYS THAT THE JUVENILE HAD BEEN CONFINED. {¶35} Here, J.L. argues that the January 16, 2026, dispositional sentencing entry stated that he was to be given credit for time served in detention “for the time set forth in the Detention Credit Addendum which is incorporated herein by reference.” However, no addendum was attached nor was it filed on the docket. J.L. submits that this failure violates the plain language of R.C. 2152.18(B) which requires that the court “state in the order of commitment the total number of days that the child has been confined in connection with the delinquent child complaint upon which the order of commitment is based.” {¶36} As previously noted, a juvenile court’s dispositional sentence in a delinquency case is generally reviewed for an abuse of discretion. In re A.P., 2025-Ohio-219, at ¶ 13 (9th Dist.). However, as the only issue raised on appeal is whether the trial court correctly calculated J.L.’s confinement credit, it is “purely a legal issue” that will be reviewed de novo. Id. {¶37} The State concedes error here and agrees with J.L. that the January 16, 2026, judgment entry omitted the addendum setting forth J.L.’s credit for time served and thus did not  15 properly include confinement credit as required by R.C. 2152.18(B). We agree with the parties that the trial court erred as a matter of law in omitting the addendum specifying J.L.’s credit for time served. {¶38} Accordingly, J.L.’s fourth assignment of error is sustained, and the matter is remanded to the trial court for the limited purpose of issuing an order correcting the error in its judgment entry regarding the amount of J.L.’s pre-dispositional confinement credit. ASSIGNMENT OF ERROR 6. THE TRIAL COURT COMMITTED REVERSIBLE AND PLAIN ERROR IN IMPOSING COURT COSTS UNDER MAR[S]Y’S LAW WITHOUT DETERMINING WHETHER THE JUVENILE WAS INDIGENT WITH RESPECT TO THE PAYMENT OF THOSE COSTS. {¶39} During the January 12, 2026, hearing, the court stated its intention to impose Marsy’s law costs. Consistent with its oral pronouncement, the court ordered J.L. to pay $30.00 as Marsy’s law costs in the January 16, 2026, judgment entry. J.L. argues here that the court ordered the payment of costs without considering his indigency or ability to pay that amount. J.L. acknowledges that R.C. 2743.70(A)(2) provides for the imposition of costs of $30.00. However, he states that R.C. 2151.54 provides that the court has authority to waive those costs upon a determination that the child is indigent. He argues that the court erred by failing to evaluate whether he was indigent for purposes of determining whether it was appropriate to waive the $30.00 court costs. {¶40} J.L.’s trial counsel did not object during the hearing to the court’s intention to order J.L. to pay Marsy’s law costs. Therefore, J.L. has forfeited all but plain error for purposes of appeal. State v. Krowiak, 2022-Ohio-413, ¶ 37 (9th Dist.). J.L. argues that the court’s order constitutes plain error because it was imposed “on the mistaken belief that it was required, and not waivable  16 . . . [and] upon an incorrect interpretation of the law[.]” The plain error standard requires that an appellant establish all of the following: First, an error, i.e., a deviation from a legal rule, must have occurred. Second, the error complained of must be plain, that is, it must be an obvious defect in the trial proceedings. Third, the error must have affected substantial rights. We have interpreted this . . . to mean that the trial court’s error must have affected the outcome of the [case]. (Internal quotations and citations omitted.) State v. Morgan, 2017-Ohio-7565, ¶ 36. J.L. states that he was prejudiced by this obvious error as he is now responsible for costs that would have otherwise been waived. {¶41} First, the trial court’s dispositional entry did not state that the imposition of the fee was required as J.L. alleges. Therefore, to the extent that J.L.’s argument is premised on the court’s ruling that costs were mandatory, that premise is false. Furthermore, J.L. did not allege at trial that he was indigent or unable to pay the $30 fee. Thus, without any indication in the record that J.L. was unable to pay the $30 court costs, the trial court’s imposition of costs was not an “obvious defect in the trial proceedings.” Morgan at ¶ 36. Finally, J.L. does not cite to any legal authorities requiring the court to sua sponte inquire into a defendant’s ability to pay or to conduct a hearing on that issue before imposing Marsy’s law costs, and the plain terms of the statute does not impose such a requirement. See App.R. 16(A)(7) (appellant’s brief must include an argument containing “citations to the authorities [and] statutes . . . on which appellant relies.”) {¶42} For all these reasons, J.L. has not carried his burden of demonstrating on appeal that the juvenile court’s imposition of Marsy’s law court costs in the amount of $30 constituted plain error and should be reversed. J.L.’s sixth assignment of error is overruled.  17 III. {¶43} Based on the foregoing, J.L’s first, second, third, fifth, and sixth assignments of error are overruled, and his fourth assignment of error is sustained. The matter is affirmed in part, reversed in part, and remanded for further proceedings consistent with this decision. Judgment affirmed in part, reversed in part, and cause remanded. There were reasonable grounds for this appeal. We order that a special mandate issue out of this Court, directing the Court of Common Pleas, County of Summit, State of Ohio, to carry this judgment into execution. A certified copy of this journal entry shall constitute the mandate, pursuant to App.R. 27. Immediately upon the filing hereof, this document shall constitute the journal entry of judgment, and it shall be file stamped by the Clerk of the Court of Appeals at which time the period for review shall begin to run. App.R. 22(C). The Clerk of the Court of Appeals is instructed to mail a notice of entry of this judgment to the parties and to make a notation of the mailing in the docket, pursuant to App.R. 30. Costs taxed equally to both parties. SCOT STEVENSON FOR THE COURT HENSAL, P. J. LANZINGER, J. CONCUR.  18 APPEARANCES: NEIL P. AGARWAL, Attorney at Law, for Appellant. ELLIOT KOLKOVICH, Prosecuting Attorney, and C. RICHLEY RALEY, JR., Assistant Prosecuting Attorney, for Appellee.