J.A.H. v. State
198 So. 3d 884
| Fla. Dist. Ct. App. | 2016Background
- In 2009 J.A.H. was charged with two offenses: trafficking in oxycodone (section 893.135) and withholding information from a practitioner ("doctor shopping").
- J.A.H. pled to the doctor-shopping count; the State entered nolle prosequi on the trafficking count. Adjudication was withheld and he received 24 months probation, terminated early in 2012.
- In August 2015 FDLE issued a certificate of eligibility to seal the records; J.A.H. filed a sealing petition in September 2015.
- The State filed a written objection arguing (1) the trafficking charge under section 893.135 barred sealing under sections 943.0585/943.059, and (2) the certificate of eligibility was not properly filed; J.A.H. replied and attached the certificate.
- The trial court denied the petition without an evidentiary hearing and without articulating reasons, stating only that the State had objected; the court later denied rehearing. J.A.H. appealed.
Issues
| Issue | Plaintiff's Argument (J.A.H.) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether trial court must hold an evidentiary hearing before denying a sealing petition | Trial court must hold a hearing and allow evidence before denying | Court may deny based on filings and objections | Court held hearing required; summary denial was abuse of discretion |
| Whether trial court must state specific reasons based on case facts when denying sealing | Must provide good reasons tied to "facts and circumstances of the individual case" | Generalized denial based on State objection was sufficient | Court held trial court must state specific, case-based reasons if it denies |
| Whether a nolle prosequi on a §893.135 charge still bars sealing under §943.059 | Nolle prosequi does not meet statutory bar because petitioner did not plead or get convicted | State argued the §893.135 charge barred sealing despite nolle prosequi | Court agreed the State’s application was incorrect but declined to decide because denial lacked reasons/hearing |
| Whether trial court relied on erroneous statutory interpretation in denying petition | Court improperly accepted State’s incorrect statutory reading | State defended its statutory interpretation | Court declined to resolve given unclear basis for denial; remanded for hearing |
Key Cases Cited
- Borg v. State, 169 So.3d 261 (Fla. 4th DCA) (trial court must give good reasons tied to individual case when denying sealing)
- Gotowala v. State, 184 So.3d 568 (Fla. 4th DCA) (summary denial reversed; hearing or written specific reasons required)
- Anderson v. State, 692 So.2d 250 (Fla. 3d DCA) (when statutory requirements met petitioner presumptively entitled to sealing)
- Godoy v. State, 845 So.2d 1016 (Fla. 3d DCA) (trial court must consider all facts and circumstances before denying sealing)
Outcome: Reversed and remanded with instruction to hold an evidentiary hearing and, if denying again, enter a written order stating specific, case-based reasons.