State v. Meads

Summary

The Ohio Third District Court of Appeals reversed Marion Municipal Court judgments denying Nicholas Meads's applications to seal records relating to dismissed criminal charges. The court held that the trial court applied the wrong statute, R.C. 2953.32 instead of R.C. 2953.33, and improperly considered victim statements when evaluating the sealing of records for dismissed charges. The matters were remanded for further proceedings.

Holdings

1. An application to seal records relating to criminal charges that were dismissed is governed by R.C. 2953.33, rather than R.C. 2953.32, which applies to records involving convictions.
2. When deciding an application under R.C. 2953.33 for records of charges dismissed without a conviction, the court may not consider victim statements as a factor in determining the government's legitimate need to retain the records.
3. The trial court's judgments were contrary to law because it applied the wrong statute and considered a factor not permitted under R.C. 2953.33.

Questions Presented

1. Whether the trial court applied the correct statute when deciding Meads's application to seal records of dismissed criminal charges.
2. Whether the trial court improperly considered the victim's statements when determining whether records of dismissed charges should be sealed.
3. Whether the trial court's denial of the applications was contrary to law.

Disposition

reversed_and_remanded