State v. Spohr, 2012 Ohio 556

Spohr was charged with assault and domestic violence in 2006; he was acquitted of the domestic-violence charge and convicted of disorderly conduct for the same conduct.
Spohr later sought to seal only the records of his domestic-violence acquittal, acknowledging he could not expunge the disorderly-conduct conviction.
The trial court granted sealing; the State appealed.
Statutes govern expungement (R.C. 2953.31 et seq.) and sealing after acquittal (R.C. 2953.52 et seq.); R.C. 2953.61 governs two-or-more-offenses scenarios.
The appellate court held that the plain statutory language barred sealing of the domestic-violence acquittal because Spohr cannot satisfy the prerequisites (including the first-offender requirement) applicable to the related conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Spohr may seal the domestic-violence acquittal despite first-offender limits.	State argues 2953.61 requires compliance with 2953.32/A(1) and 2953.52, blocking sealing here.	Spohr contends 2953.52(A)(1) governs timing only and lacks a first-offender hurdle.	Sealing is barred; plain language requires first-offender eligibility, which Spohr lacks.
How 2953.61 interacts with 2953.32 to govern sealing after differing dispositions.	State argues 2953.61 unambiguously ties timing to eligibility under 2953.32.	Spohr argues 2953.61 only sets timing, not eligibility; Hankins-like reasoning not applicable.	Statutes require eligibility under 2953.32 before sealing under 2953.52; Spohr is ineligible.

State v. Futrall, 123 Ohio St.3d 498 (2009-Ohio-5590) (de novo review of legal questions in expungement/sealing context; standard applied)
State v. Kreischer, 109 Ohio St.3d 391 (2006-Ohio-2706) (statutory language plain; no need for interpretive tools)
State v. Pierce, 2007-Ohio-1708 (10th Dist. 2007) (expungement/sealing framework; abuse-of-discretion/de novo aspects)