State v. Black, 2015 Ohio 4256

In 2009 Aleicia Black was convicted of a fifth-degree felony (possession of controlled substances) and sentenced to 2 years community control with a 150-hour community service requirement.
In 2011 probation was terminated as "Unsuccessful" after Black had not completed her community service; the court did not revoke probation.
Black completed additional volunteer hours (116.17) after termination and applied on August 4, 2014 to have her conviction records sealed under R.C. 2953.32.
The State objected, arguing she had not completed the community service component and had not satisfied the statutory waiting period.
The trial court granted the sealing application after finding Black satisfied the discretionary factors in R.C. 2953.32(C).
The court of appeals reversed, holding Black was not an "eligible offender" because the mandatory three-year waiting period following "final discharge" had not expired at the time the trial court ordered sealing.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court had jurisdiction to seal Black's felony conviction records	The State: Black was ineligible because she had not satisfied the statutory waiting period after final discharge	Black: She completed the community service component after termination and met R.C. 2953.32(C) factors, so sealing was proper	The court held Black was not eligible; the trial court lacked jurisdiction because the three-year waiting period after final discharge had not expired

State ex rel. Gains v. Rossi, 86 Ohio St.3d 620 (1999) (sealing statutes are remedial and construed liberally)
Barker v. State, 62 Ohio St.2d 35 (1980) (context for liberal construction and remedial statutes)
State v. Pettis, 133 Ohio App.3d 618 (1999) (restitution and sentence components affect final discharge analysis)
In re White, 165 Ohio App.3d 288 (2006) (discussing completion of sentence components for sealing eligibility)