State v. Boykin, 138 Ohio St. 3d 97

Boykin received a gubernatorial pardon for four offenses (1991 thefts and 1992 RSP) after prior convictions from 1987–2007.
She sought to seal three pardoned convictions in Summit and Akron courts.
Lower courts denied sealing, invoking nonautomatic nature of sealing and Pepper Pike balancing.
Ninth District certified a conflict with Cope and the Ohio Supreme Court granted discretionary review to decide if a pardon automatically seals pardoned offenses.
Court held that a gubernatorial pardon does not automatically entitle sealing of pardoned convictions; sealing is not compelled by a pardon and depends on statute and balancing under Pepper Pike.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Does a gubernatorial pardon automatically seal pardoned convictions?	Boykin contends pardon automatically entitles sealing.	State/City argues no automatic entitlement; sealing requires statutory process and balancing.	No automatic sealing; paternal discretion remains with statutes and equity balancing.

Pepper Pike v. Doe, 66 Ohio St.2d 374 (1981) (expungement limited to exceptional cases; not automatic for nonconvicted or pardoned)
Cope v. State, 111 Ohio App.3d 309 (1996) (conflict on pardon expungement; not controlling here)
Knapp v. Thomas, 39 Ohio St. 377 (1883) (pardon discussed in 読 dicta; not controlling about sealing)
State ex rel. Hawkins v. State, 44 Ohio St. 98 (1886) (discussed longevity of consequences despite pardon)
Angle v. Chicago,, etc., 151 U.S. 1 (1894) (pardons relieve punishment but not civil liability; limits of pardon)
Burdick v. United States, 236 U.S. 79 (1915) (pardon carries imputation of guilt; does not erase past)
Ex parte Garland, 71 U.S. 333 (1866) (pardon language dicta; limited applicability)
Knote v. United States, 95 U.S. 149 (1877) (pardon releases from consequences but not amends for past)