State v. Bartrum

{¶ 1} In this case, we accepted the state of Ohio’s sole proposition of law to determine whether an actual minor must exist in order to convict a defendant of a violation of former R.C. 2907.21(A)(3), compelling prostitution of a minor. Because the statute is ambiguous and therefore must be strictly construed against the state, we hold that under former R.C. 2907.21(A)(3) (now R.C. 2907.21(A)(3)(a)), a defendant may not be convicted of compelling prostitution unless an actual minor exists.

I. Case Background

{¶ 2} For agreeing to pay $500 in exchange for sexual activity involving a woman and…