State v. Reiner, 2016 Ohio 5520

In July 2002 Timothy Reiner was charged with two counts of attempted aggravated murder of police officers; after a psychiatric evaluation he was found not guilty by reason of insanity and civilly committed.
In November 2012 the trial court terminated his commitment; in February 2015 Reiner applied under R.C. 2953.52 to seal his arrest records.
At the October 2015 hearing Reiner testified the public record prevented him from obtaining suitable employment despite an accounting degree.
The state opposed sealing, citing the seriousness of the charges, the life‑threatening injuries to the officers, and public/police safety interests in maintaining the record.
The trial court denied the sealing application after weighing Reiner’s interest against the government’s legitimate needs, and Reiner appealed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court abused its discretion by denying sealing under R.C. 2953.52	State: government has a legitimate need to retain the record given the nature of the offenses and serious injuries to officers; public and police safety warrant transparency	Reiner: sealing is appropriate because he was found not guilty by reason of insanity and needs records sealed to obtain employment; state relied only on nature of charge	Court: no abuse of discretion — state articulated legitimate interests (serious injuries, mental‑health history, safety/transparency) that outweighed Reiner’s interest

Blakemore v. Blakemore, 5 Ohio St.3d 217 (Ohio 1983) (defines abuse of discretion standard)
State v. Hilbert, 145 Ohio App.3d 824 (8th Dist. 2001) (nature of offense alone cannot be sole basis to deny sealing)