In re K.B

In In re K.B., 2007 Ohio 1647 at P22, the Court found structural error to exist where a juvenile court made "repeated statements regarding a juvenile delinquent's silence" and stated that it viewed the delinquent's "failure to testify as 'critical.'" Id. Specifically, the Court found that the juvenile court's statements "strongly suggest a shift in the burden of proof from the state to the juvenile delinquent, requiring the delinquent to explain his conduct," and that "such a shift in the burden of proof fundamentally impacts how the trier of fact makes its ultimate decision." Id.