State v. Reed, 2021 Ohio 406

On April 2, 2019, David Reed was stopped while driving a golf cart on Memorial Shoreway and cited under R.C. 4511.214(A)(2) (low-speed/under-speed vehicle).
Reed was tried to the court on August 7, 2019; the court found him guilty.
On October 25, 2019, the court imposed a $10 fine plus costs (total $125); Reed paid the full sanction the same day.
Reed filed a notice of appeal on November 8, 2019 and did not seek a stay of execution of sentence pending appeal.
The City of Port Clinton moved (in its brief) to dismiss the appeal as moot because Reed voluntarily served his sentence and did not show any collateral disability or loss of civil rights from the conviction.
The Sixth District dismissed the appeal as moot and ordered Reed to pay appellate costs; it noted in the alternative that, were the case not moot, it would affirm due to the absence of the trial transcript.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether R.C. 4511.214 applies to a private roadway	Reed: the road was private so the statute does not govern his conduct	City: appeal is moot because Reed voluntarily completed his sentence and showed no collateral consequences	Appeal dismissed as moot; court did not reach merits (alternative: would affirm for lack of trial transcript)

State v. Golston, 71 Ohio St.3d 224, 643 N.E.2d 109 (explaining that a voluntarily served misdemeanor sentence renders an appeal moot absent collateral consequences)
Cleveland Heights v. Lewis, 129 Ohio St.3d 389, 953 N.E.2d 278 (discussing requirement to show collateral disability or loss of civil rights to avoid mootness)
Knapp v. Edwards Laboratories, 61 Ohio St.2d 197, 400 N.E.2d 384 (where necessary portions of the trial transcript are omitted, appellate court presumes validity of lower court proceedings and affirms)