State v. Bergman, 2017 Ohio 2944

David Bergman had four felony convictions in Union County (2005) and one felony conviction in Delaware County (2005) arising from drug offenses dated in 2004.
Bergman filed a motion (Sept. 21, 2016) to expunge/seal his criminal record under Ohio's expungement statute.
The trial court denied the motion without holding a hearing, finding Bergman ineligible under R.C. 2953.31(A) because he had multiple felony convictions.
Bergman argued the convictions were "connected" or arose from related acts close in time and should be counted as one conviction for eligibility.
The trial court relied on documentary differences (different counties and dates) but did not hold the hearing required by R.C. 2953.32(B).
The Fifth District reversed, holding that because Bergman raised a factual dispute about whether convictions were "connected with the same act," a hearing was required before denying the motion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a court may deny an expungement motion without a hearing when the applicant appears ineligible due to multiple convictions	State: Bergman is ineligible under R.C. 2953.31(A) (multiple felony convictions); no hearing required when ineligibility is clear	Bergman: Convictions were closely related in time and fact and should be treated as one conviction; statute mandates a hearing under R.C. 2953.32(B)	Court: Reversed and remanded — where the applicant raises a factual dispute about eligibility (e.g., whether convictions are "connected"), the trial court must hold the hearing required by R.C. 2953.32(B) before denying relief

State v. Grillo, 27 N.E.3d 951 (Ohio Ct. App.) (hearing requirement on expungement motion explained)
State v. Wright, 947 N.E.2d 246 (Ohio Ct. App.) (trial court must hold hearing where factual disputes about first-offender status or related-conviction counting exist)