State v. T.M., 2014 Ohio 5688

In 1992 T.M. pleaded guilty to a third‑degree felony drug‑trafficking offense and was sentenced to 18 months imprisonment; a nunc pro tunc entry later imposed a mandatory $5,000 fine and court costs.
T.M. completed his prison term but did not pay the fine or court costs.
T.M. moved to seal (expunge) his record in 2004; the sealing hearing did not occur until 2013–2014.
At the 2014 hearing the trial court found T.M. indigent and journalized an entry waiving the $5,000 fine and granting the sealing of the conviction record.
The State appealed, arguing the trial court lacked jurisdiction to waive (or retroactively suspend) a mandatory fine and that T.M. had not reached “final discharge” because the fine remained unpaid.
The appellate court reversed: it held the trial court exceeded its limited continuing jurisdiction by waiving (vacating) the fine rather than suspending it and that final discharge had not occurred, so sealing was improper.

Issue	Plaintiff's Argument (State)	Defendant's Argument (T.M.)	Held
Whether the trial court had jurisdiction to waive or modify the mandatory fine after sentence was final	The court lost jurisdiction after final judgment and cannot waive or modify the mandatory fine; at most it could suspend under statutory authority but cannot vacate	The court retained authority under R.C. 2929.18(G) (and its predecessor) to suspend/relieve the financial sanction and should be able to consider indigency	Court: Trial court exceeded jurisdiction by waiving (vacating) the fine; only suspension (not waiver) is authorized and the court lacked authority to void the fine retroactively
Whether T.M. was eligible to seek sealing because he had not achieved “final discharge” due to unpaid fine	The unpaid mandatory fine is part of the sentence; final discharge has not occurred, so the statutory waiting period for sealing (three years for a felony) has not begun	T.M. argued the court’s action (waiver/suspension) and/or equitable considerations render him eligible	Court: Because the fine remains (trial court’s vacating was void), final discharge did not occur and sealing was improper; appellate court reversed sealing order

State ex rel. Hansen v. Reed, 63 Ohio St.3d 597 (Ohio 1992) (a criminal judgment is final when journalized; court may not reconsider a valid final judgment)
State v. Fischer, 128 Ohio St.3d 92 (Ohio 2010) (distinguishes void sanctions from valid sanctions subject to res judicata in sentencing challenges)
Hernandez v. Kelly, 108 Ohio St.3d 395 (Ohio 2006) (addresses trial court jurisdiction limits after sentence served)
State v. Holdcroft, 137 Ohio St.3d 526 (Ohio 2013) (clarifies interplay of Fischer and Hernandez re: sentencing jurisdiction)
State v. Simpkins, 117 Ohio St.3d 420 (Ohio 2008) (sentences not authorized by statute are void and may be corrected; but completion of sentence may limit resentencing)