State v. M.D., 2015 Ohio 4003

In 1987 M.D. pled guilty to third-degree grand theft with a physical-harm specification; she received 90 days jail and three years probation and completed probation in 1991.
In 2013 M.D. applied to expunge/seal the conviction but conceded she was statutorily ineligible for expungement.
M.D. sought relief under the trial court’s inherent authority to seal records, arguing privacy interests and special circumstances warranted expungement.
The trial court denied the application solely on statutory-ineligibility grounds (crime of violence), without addressing inherent authority.
M.D. appealed; the court of appeals considered whether the trial court erred by failing to consider its inherent authority under recent Ohio precedent.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by denying M.D.’s request to seal/expunge without addressing the court’s inherent authority to do so	M.D. conceded statutory ineligibility but argued the court could order expungement under its inherent authority to protect privacy given unusual/special circumstances	State relied on statutory ineligibility (crime of violence) to oppose sealing and the trial court denied on that basis	The appeals court held the trial court erred by failing to address inherent authority under controlling precedent and remanded for the trial court to consider that claim (no ruling on merits)

Pepper Pike v. Doe, 66 Ohio St.2d 374 (Ohio 1981) (trial courts may order expungement in unusual and exceptional circumstances)
State v. Radcliff, 142 Ohio St.3d 78 (Ohio 2015) (limits courts’ extrastatutory expungement authority largely to acquittals/exonerations and urges restraint in sealing convictions)