Dunbar v. State, 136 Ohio St. 3d 181

Dunbar struck his live-in fiancée and was charged with domestic violence, pleading no contest in municipal court and receiving a 180‑day sentence.
In 2005, Dunbar was indicted on felony abduction and domestic-violence counts and pleaded guilty to one abduction count under a plea agreement; the trial court imposed a two-year prison term.
On appeal, the Eighth District reversed the conviction and remanded to vacate Dunbar's plea; on remand, a jury convicted him of one abduction count and he was again sentenced to prison, a conviction later vacated by the court of appeals.
Dunbar filed a complaint in the Cuyahoga County Court of Common Pleas seeking to be declared a wrongfully imprisoned person under R.C. 2743.48(B)(2) and (E). The Eighth District’s decision was reviewed; the court ultimately held the guilty plea precludes eligibility under R.C. 2743.48(A)(2).
The Supreme Court’s decision interprets R.C. 2743.48(A)(2) to bar recovery for anyone who pled guilty, even if the plea was later vacated on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does a vacated guilty plea bar eligibility under R.C. 2743.48(A)(2)?	Dunbar argues the plea's vacatur voids its effect, so he should qualify.	The State argues the plain text precludes anyone who pled guilty, regardless of vacatur.	No; vacancy does not remove disqualification; plain-language bar applies.
Should R.C. 2743.48 be read as ambiguous to permit an exception for vacated pleas?	Statute remedial; vacated pleas should be treated as not precluding recovery.	Statute language is clear; no exception for vacated pleas.	Statute not ambiguous; no exception implied by the text.
Is there a constitutional or statutory basis to create a new exception for vacated pleas?	Legislative intent favors liberal construction of remedial statutes.	Only the General Assembly may create such an exception.	Only the General Assembly can create exceptions; court cannot read one in.
What is the court's ultimate ruling on Dunbar's eligibility for wrongful imprisonment damages?	N/A	N/A	Reversed the Eighth District; dismissed Dunbar's claim for wrongful imprisonment.

Doss v. State, 135 Ohio St.3d 211 (2012-Ohio-5678) (two-step wrongful-imprisonment framework; required five conditions for eligibility)
Walden v. State, 47 Ohio St.3d 47 (1989) (statutory remedial scheme; separation of wrongfully imprisoned from those avoiding liability)
Griffith v. Cleveland, 128 Ohio St.3d 35 (2010-Ohio-4905) (syllabus on separation of wrongfully imprisoned from other outcomes)
State v. Moore, 847 N.E.2d 452 (2006-Ohio-114) (Fourth Dist.; discussion of voidness of pleas in certain contexts)
Pratts v. Hurley, 102 Ohio St.3d 81 (2004-Ohio-1980) (syllabus guidance on void vs voidable judgments)