State v. W.C., 2022 Ohio 3235

In 2014 W.C. was indicted on 31 counts (various unauthorized use, tampering, forgery, possessing criminal tools); he pled in 2015 to tampering with records (first‑degree misdemeanor) and an amended fifth‑degree felony for unauthorized use of property; remaining counts were nolled.
The court sentenced W.C. to two years of community control (conditions included 500 hours community service, cultural sensitivity counseling, monthly supervision fees); he later violated supervision and served a six‑month jail term.
On February 3, 2020 W.C. moved to seal his conviction record under R.C. 2953.32; the state opposed, citing its interest in maintaining the record and W.C.’s failure to complete community control as relevant to rehabilitation.
Two hearings were held; W.C. emphasized eligibility, lapse of the statutory waiting period, rehabilitation (including college degrees and ongoing education), and employment barriers caused by the felony.
The trial court denied the motion by journal entry without explaining its reasoning. The state conceded at oral argument on appeal that the trial court failed to make the requisite findings on the record.
The Eighth District reversed and remanded, holding the trial court must state findings demonstrating compliance with R.C. 2953.32(C)(1) so an appellate court can meaningfully review the exercise of discretion.

Issue	State's Argument	W.C.'s Argument	Held
Whether the trial court made the factual/legal findings required by R.C. 2953.32(C)(1) when denying a sealing motion	The state opposed sealing and argued the court should consider its legitimate need to keep the record and W.C.’s unsuccessful completion of community control	W.C. argued he was an eligible offender, the waiting period had passed, no proceedings were pending, he was rehabilitated (educational achievements) and his interest outweighed the State’s	The court held the record lacks any articulated findings; reversal and remand required so the trial court can state its R.C. 2953.32(C)(1) analysis
Whether the denial was an abuse of discretion on the merits (weighing rehabilitation vs. government interest)	The state contended its interest and the supervision violations supported denial	W.C. contended the record showed rehabilitation and collateral harms from an unsealed record	The merits were not reached: because the trial court failed to explain its ruling, appellate review was not possible and the matter was remanded for findings

State v. Lasalle, 96 Ohio St.3d 178 (holding the statute in effect at the time the motion is filed governs)
State v. Petrou, 13 Ohio App.3d 456 (recognizing sealing statutes serve rehabilitation and forgiveness interests)
State v. Boddie, 170 Ohio App.3d 590 (discussing the policy rationale for sealing and legislative intent)