State v. C.A., 2014 Ohio 2621

On May 30, 2012, appellee was stopped and cited for speeding, OVI (R.C. 4511.19), and four drug-related offenses; the drug charges were prosecuted in two municipal-court cases and the OVI in a separate case.
The drug charges were ultimately dismissed after appellee completed a specialty docket program; appellee did not seek sealing of the OVI conviction.
Appellee filed R.C. 2953.52 applications to seal the records of the dismissed drug-related cases; the city and state objected, citing R.C. 2953.61 and the existing OVI conviction.
The municipal court granted sealing of the dismissed drug-related cases despite the OVI conviction; the city and state appealed and the appeals were consolidated.
The central procedural question is whether the trial court erred by sealing dismissed charges without first determining whether those charges "arose as a result of or in connection with the same act" as the unsealable OVI conviction, as required by State v. Pariag.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 2953.61 precludes sealing dismissed drug charges when an unsealable conviction (OVI) arose from the same act	R.C. 2953.61 (as interpreted in Pariag) bars sealing if the dismissed charges arose from the same act as the unsealable conviction; facts (same stop, same officer, same date) show they did	Trial court properly sealed dismissed drug charges; no explicit determination required or records show separateness	Reversed and remanded: trial court erred by sealing without first determining whether the dismissed charges and the OVI "arose as a result of or in connection with the same act." Court must make that factual/legal determination first

State v. Pariag, 137 Ohio St.3d 81 (Ohio 2013) (holds R.C. 2953.61 precludes sealing dismissed charges if they arose "as the result of or in connection with the same act" as a conviction that is exempt from sealing)