State v. Manocchio, 138 Ohio St. 3d 292

Giovanni A. Manocchio convicted in 2003 of a felony third‑degree DUI and received a lifetime driver’s‑license suspension.
He sought termination/modification in 2008 (denied) and, in 2012, moved for limited driving privileges. The trial court granted privileges "solely during daylight hours."
The State appealed, arguing former R.C. 4510.54(A) barred any modification or restoration within the first 15 years of a lifetime suspension.
The Eighth District Court of Appeals (divided) held that limited driving privileges are not a “modification or termination” of a suspension and therefore could be granted.
The Supreme Court of Ohio considered whether a court may grant limited privileges within the first 15 years and whether the trial court’s entry complied with statutory requirements.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a trial court may grant limited driving privileges during the first 15 years of a lifetime suspension	Granting privileges modifies the suspension and is prohibited by former R.C. 4510.54(A)	Limited privileges are distinct from modification/termination and are expressly authorized by R.C. 4510.021(A) during any suspension	Granting limited driving privileges (if entry complies with R.C. 4510.021(A)) is not a modification/termination prohibited by former R.C. 4510.54(A); court may grant them
Whether the trial court’s entry granting ‘‘daylight hours’’ privileges complied with R.C. 4510.021(A)	N/A (State argued grant itself improper)	Manocchio relied on the court’s discretion; entry was treated as sufficient by trial court	The entry failed to satisfy R.C. 4510.021(A) because it did not specify an authorized limited purpose or places; remanded for a compliant entry

Klemas v. Flynn, 66 Ohio St.3d 249 (Ohio 1993) (statutory construction principles: words read in context and technical meanings respected)