State v. Smith, 2014 Ohio 2232

Smith, a prior 1996 drug-trafficking conviction in Medina County, sought to seal that record.
Nevada, 2002: Smith pleaded guilty to conspiracy to commit grand larceny auto, a gross misdemeanor; other counts dismissed.
2013: Smith filed an application to seal his Medina County drug conviction; State initially indicated no objection.
Trial court held a first hearing but paused to verify Nevada case status and later denied the sealing application, inviting proof that Nevada case was not a conviction.
Smith submitted a motion for reconsideration with Nevada pleadings; a second hearing occurred, after which the court again denied.
This appeal followed; the Ninth District held the court failed to properly apply RC 2953.32(C) and reversed remanding for correct analysis.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether court properly weighed interests under RC 2953.32(C).	Smith argues court failed to weigh applicant’s seal interest against State’s interest.	Smith’s interests should be considered; State objected minimally.	Remanded for proper weighing of interests.
Whether court properly determined rehabilitation under RC 2953.32(C).	Smith argues court should assess rehabilitation satisfactory to the court.	Court must evaluate rehabilitation but record lacked explicit finding.	Remanded to determine rehabilitation.
Whether denial was ripe for appellate review.	N/A; argument focused on error in procedure.	N/A.	Not ripe; court will review on remand.

State v. Hamilton, 75 Ohio St.3d 636 (Ohio 1996) (expungement is a grace, not a constitutional right)
State v. Widder, 146 Ohio App.3d 445 (9th Dist.2001) (requires weighing interests and rehabilitation on remand)
State v. Stringer, 2009-Ohio-909 (9th Dist.2009) (requires proper consideration of rehabilitation and statutory factors)