State v. Mbodji

{¶ 1} The issue before us is whether a trial court has subject-matter jurisdiction to proceed against a defendant when a private citizen signs a complaint and affidavit charging the defendant with a crime but the complaint and affidavit are not reviewed by a reviewing official pursuant to R.C. 2935.09. We hold that a complaint that meets the requirements of Crim.R. 3 invokes the subject-matter jurisdiction of a trial court. When a complaint and affidavit are signed by a private citizen but are not reviewed by a reviewing official before filing pursuant *326to R.C. 2935.09, the defect is not…