State v. Young, 2022 Ohio 593

Dec. 8, 1992: Young was stopped and charged with OVI (in Mt. Gilead Mayor’s Court) and drug possession; OVI prosecuted separately in mayor’s court.
Feb. 3, 1993: Grand jury in Morrow County indicted Young for possession; Sept. 16, 1993: Young pled to Attempted Drug Abuse (first-degree misdemeanor) in Morrow County; sentencing entered Sept. 24, 1993 (jail suspended on conditions).
Mar. 1, 2021: Young moved in Morrow County Common Pleas to seal the record of the 1993 Attempted Drug Abuse conviction under R.C. §2953.32.
Trial court denied the motion (June 25, 2021), finding Young was not an "eligible offender" under R.C. §2953.31(A)(1).
On appeal, the Fifth District reviewed statutory interpretation de novo and factual findings for abuse of discretion, concluded the trial court erred, and held Young is an eligible offender; case reversed and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Young is an "eligible offender" under R.C. §2953.31(A)(1)	State argued Young was not eligible (trial court found ineligible), asserting the convictions were sufficiently connected to bar sealing.	Young argued he is eligible because the Morrow County conviction is a single misdemeanor conviction; the OVI was a separate charge in a different court and the offenses arise from distinct facts.	Court held Young is an eligible offender: the OVI and drug convictions were prosecuted in separate jurisdictions, with separate case numbers, pleas, and distinct factual bases; remanded to consider sealing on the merits.
Whether alleged clerical burden or cross-references to other records (e.g., OVI police reports) justified denying sealing	State contended sealing would impose undue clerical burden and might leave related records (e.g., OVI reports) accessible.	Young argued the speculative clerical burden did not outweigh his privacy interest and offered no proof the reports still exist or must remain unsealed.	Court rejected State's burden argument as unsupported by the record and prioritized appellant's privacy interest; no heavy clerical-burden justification found.

Blakemore v. Blakemore, 5 Ohio St.3d 217 (1983) (defines abuse of discretion standard)
State v. Futrall, 123 Ohio St.3d 498 (2009) (statutory interpretation reviewed de novo)
State v. Pariag, 137 Ohio St.3d 81 (2013) (statutory interpretation is a question of law)
State v. Hamilton, 75 Ohio St.3d 636 (1996) (expungement is statutory privilege; court may only grant when statutory requirements met)
State v. Simon, 87 Ohio St.3d 531 (2000) (expungement is a privilege, not a right)
State ex rel. Gains v. Rossi, 86 Ohio St.3d 620 (1999) (sealing statutes are remedial and construed liberally)