Hopkins v. Certificate of Qualification for Emp.

2025 Ohio 1072
CourtOhio Court of Appeals
DecidedMarch 27, 2025
Docket24AP-502
StatusPublished

This text of 2025 Ohio 1072 (Hopkins v. Certificate of Qualification for Emp.) is published on Counsel Stack Legal Research, covering Ohio Court of Appeals primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Hopkins v. Certificate of Qualification for Emp., 2025 Ohio 1072 (Ohio Ct. App. 2025).

Opinion

[Cite as Hopkins v. Certificate of Qualification for Emp., 2025-Ohio-1072.]

IN THE COURT OF APPEALS OF OHIO

TENTH APPELLATE DISTRICT

:

Wayne M. Hopkins, : No. 24AP-502 (C.P.C. No. 24MS-0239) Petitioner-Appellant, : (REGULAR CALENDAR) v. :

Certificate of Qualification : for Employment, : Respondent-Appellee. :

D E C I S I O N

Rendered on March 27, 2025

On brief: Wayne M. Hopkins, pro se. Argued: Wayne M. Hopkins.

On brief: [Shayla D. Favor], Prosecuting Attorney, and Seth L. Gilbert, for appellee. Argued: Seth L. Gilbert.

APPEAL from the Franklin County Court of Common Pleas

EDELSTEIN, J.

{¶ 1} Petitioner-appellant, Wayne M. Hopkins, appeals from a judgment entry of the Franklin County Court of Common Pleas denying his petition for a certificate of qualification for employment (“CQE”). For the following reasons, we reverse. I. Facts and Procedural History

{¶ 2} On May 6, 2024, Mr. Hopkins filed a petition for a CQE under R.C. 2953.25. The petition stated he was convicted of felonious assault and kidnapping in 2003, both in Franklin County. Mr. Hopkins stated he was requesting a CQE to “become employed in the No. 24AP-502 2

transportation industry,” and that he is “self-employed in the industry but . . . need[s] the CQE to obtain contracts.” (Petition.) He stated he did not intend to use the CQE “to obtain an occupational license from a state licensing board” but that he did intend to obtain employment and use the CQE as a means to provide employer immunity under R.C. 2953.25(G). (Petition.) Mr. Hopkins further stated the CQE would materially assist him in obtaining transportation contracts with “the government and other businesses that require this service,” and that “[e]mployers will no longer be able to use [his] conviction as a reason to deny [him] the opportunity.” (Petition.) Mr. Hopkins stated he lives a law-abiding life and the CQE would enable him to continue to give back to his community. Lastly, Mr. Hopkins stated he does not pose an unreasonable risk to the safety of the community, reiterating he lives a law-abiding life, serves at-risk youth in his community, and travels throughout the state and country without posing any risk to the public. {¶ 3} Respondent-appellee, Franklin County Prosecuting Attorney, responded with a May 13, 2024 memorandum stating it would defer to the trial court on the question of whether the CQE should be granted. The prosecutor’s office took no position on whether Mr. Hopkins demonstrated a “collateral sanction” in his petition as defined in R.C. 2953.25(A)(1). {¶ 4} On July 16, 2024, the trial court issued a judgment entry denying Mr. Hopkins’ petition for CQE. In denying the petition, the trial court made four distinct findings: (1) Mr. Hopkins has not suffered a collateral sanction related to employment or occupational licensing as a result of his convictions; (2) Mr. Hopkins did not establish the CQE will materially assist him in obtaining employment or an occupational license; (3) Mr. Hopkins did not establish he has a substantial need for the CQE in order to live a law- abiding life; and (4) Mr. Hopkins did not establish granting the CQE would not pose an unreasonable risk of safety to the public or any individual. (July 16, 2024 Jgmt. Entry at 1- 2.) Mr. Hopkins timely appeals. II. Assignments of Error

{¶ 5} Mr. Hopkins raises the following assignments of error for our review:

[I.] The trial court erred and abused its discretion in dismissing appellant’s action. In my petition for CQE I indicated that my No. 24AP-502 3

convictions has prevented me from seeking employment contracts with the city, county, state and other employers.

[II.] The trial court erred and abused its discretion in dismissing appellant’s action. I have completed all supervision and sanctions associated with my felony convictions related to case #03 CR 004221.

(Sic passim.)

III. Discussions

{¶ 6} Mr. Hopkins’ two assignments of error are interrelated, and we address them jointly. In his first assignment of error, Mr. Hopkins argues the trial court erred in finding he did not demonstrate the existence of a collateral sanction. In his second assignment of error, Mr. Hopkins argues the trial court erred in determining he did not demonstrate entitlement to the CQE. Taken together, the two assignments of error assert the trial court erred in denying his petition for CQE. {¶ 7} R.C. 2953.25 creates a mechanism for individuals who have been convicted of or pleaded guilty to an offense, meet specified eligibility requirements, and are subject to a collateral sanction to obtain a CQE that will provide relief from certain bars to employment or occupational licensing resulting from their conviction. Tanksley v. O’Brien, 2016-Ohio-7068, ¶ 8 (10th Dist.), quoting In re Bailey, 2015-Ohio-413, ¶ 10 (8th Dist.). Where the common pleas court denies a petition for CQE, “the individual may appeal the decision to the court of appeals only if the individual alleges that the denial was an abuse of discretion on the part of the court of common pleas.” R.C. 2953.25(C)(8). Thus, we review a trial court’s denial of a petition for CQE for an abuse of discretion. In re Betsacon, 2018- Ohio-5367, ¶ 5 (10th Dist.). An abuse of discretion connotes a decision that is unreasonable, arbitrary, or unconscionable. Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 (1983); State ex rel. Deblase v. Ohio Ballot Bd., 2023-Ohio-1823, ¶ 27. {¶ 8} Before filing a petition for a CQE, an individual must satisfy a statutory waiting period of six months for misdemeanor convictions or one year for felony convictions. R.C. 2953.25(B)(4)(a)(i) and (ii). Alternatively, a petitioner may file the CQE petition immediately after release from incarceration or termination from community control if the individual satisfies certain criteria. R.C. 2953.25(B)(4)(b). Once an individual No. 24AP-502 4

files a petition that satisfies the statutory waiting period, R.C. 2953.25 provides two distinct avenues for a common pleas court to grant a CQE. The first route, contained in R.C. 2953.25(C)(3), specifies the common pleas court has discretion to issue a CQE if it finds the individual has established, by a preponderance of the evidence, all of the following:

(a) Granting the petition will materially assist the individual in obtaining employment or occupational licensing.

(b) The individual has a substantial need for the relief requested in order to live a law-abiding life.

(c) Granting the petition would not pose an unreasonable risk to the safety of the public or any individual.

{¶ 9} The second route for a common pleas court to grant a CQE, as set forth in R.C. 2953.25(C)(5) and (6), provides “an individual is rebuttably presumed to be eligible for a [CQE] if the court” finds all of the following: (a) The application was filed after the expiration of the applicable waiting period described in division (B)(4) of this section;

(b) If the offense that resulted in the collateral sanction from which the individual seeks relief is a felony, at least three years have elapsed since the date of release of the individual from any period of incarceration in a state or local correctional facility that was imposed for that offense and all periods of supervision imposed after release from the period of incarceration or, if the individual was not incarcerated for that offense, at least three years have elapsed since the date of the individual’s final release from all other sanctions imposed for that offense;

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Related

In re Bailey
2015 Ohio 413 (Ohio Court of Appeals, 2015)
In re Tanksley
2016 Ohio 7068 (Ohio Court of Appeals, 2016)
Blakemore v. Blakemore
450 N.E.2d 1140 (Ohio Supreme Court, 1983)
In re Cripps
2023 Ohio 111 (Ohio Court of Appeals, 2023)
State ex rel. DeBlase v. Ohio Ballot Bd.
2023 Ohio 1823 (Ohio Supreme Court, 2023)
In re Deran
2023 Ohio 2902 (Ohio Court of Appeals, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 1072, Counsel Stack Legal Research, https://law.counselstack.com/opinion/hopkins-v-certificate-of-qualification-for-emp-ohioctapp-2025.