State v. A.A., 2020 Ohio 508

Defendant A.A. filed (May 23, 2019) to seal records in three Franklin County cases: one felony theft (12CR-5304) and two misdemeanors (11CR-590; 13CR-2153).
The felony sentence (imposed April 22, 2013) included a restitution order of $439.00.
A.A. reduced the restitution balance to zero by depositing payments on July 25, 2019 — the day of the sealing hearing; the application was filed before restitution was fully paid.
The trial court granted sealing as to all three cases, including the felony.
The State appealed solely as to the felony sealing, arguing the application was premature because R.C. 2953.32 requires a three-year waiting period after final discharge, which occurs only after all sentencing requirements (including restitution) are satisfied.
The court of appeals reversed the sealing of the felony record and remanded to vacate that portion of the order; it did not disturb the misdemeanor seals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had jurisdiction to seal A.A.'s felony conviction when the application was filed before final discharge and before the 3-year waiting period began	State: The application was untimely because final discharge occurred only after restitution was paid (July 25, 2019), so the 3-year waiting period had not begun when the application was filed	A.A.: (implicit) eligible offender and otherwise met sealing criteria; trial court properly granted sealing	The court held the trial court lacked jurisdiction to seal the felony record because the application was filed before final discharge and before the mandatory three-year waiting period commenced; reversal and remand to vacate felony sealing

State v. Pariag, 137 Ohio St.3d 81 (2013) (R.C. 2953.32 and related provisions set limits on trial court jurisdiction to grant sealing)
State v. Aguirre, 144 Ohio St.3d 179 (2014) (final discharge does not occur until all sentencing requirements, including restitution, are satisfied)