State v. C.L.W., 2019 Ohio 1965

In 2013 C.L.W. pled guilty to one count of fifth-degree felony forgery, received one year community control, and was ordered to pay $2,500 restitution to Ohio Medicaid.
Appellee fully paid restitution on April 30, 2018 (paid $2,085 that day to satisfy outstanding balance).
On June 22, 2018, appellee filed an application to seal her conviction record under R.C. 2953.32.
The State objected, arguing appellee was not eligible because three years had not elapsed after her final discharge.
The trial court held a hearing on August 16, 2018 and granted the sealing application. The State appealed.
The Tenth District reversed, concluding the application was premature because the three-year waiting period runs from the date restitution is fully paid (final discharge).

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by sealing a conviction when the offender had not waited three years after final discharge required by R.C. 2953.32(A)(1)	The State: sealing was improper because three years had not elapsed since final discharge (restitution was paid on Apr 30, 2018)	C.L.W.: sought sealing in June 2018 (implicitly arguing eligibility or relying on trial court discretion)	Court reversed: applicant was ineligible because the three-year period had not begun until restitution was fully paid (Apr 30, 2018), so the sealing was premature and trial court lacked jurisdiction

State v. Aguirre, 144 Ohio St.3d 179 (Ohio 2014) (final discharge and three-year waiting period are threshold eligibility requirements for sealing)
State v. Boykin, 138 Ohio St.3d 97 (Ohio 2013) (trial court may seal convictions only when statutory eligibility requirements are met)
In re White, 165 Ohio App.3d 288 (10th Dist. 2006) (an offender is not finally discharged for sealing purposes while restitution remains owing)
State v. Pariag, 137 Ohio St.3d 81 (Ohio 2013) (statutory limits define trial court jurisdiction to grant sealing)