In re Cripps

2023 Ohio 111
CourtOhio Court of Appeals
DecidedJanuary 17, 2023
Docket22CA0012-M
StatusPublished
Cited by2 cases

This text of 2023 Ohio 111 (In re Cripps) 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
In re Cripps, 2023 Ohio 111 (Ohio Ct. App. 2023).

Opinion

[Cite as In re Cripps, 2023-Ohio-111.]

STATE OF OHIO ) IN THE COURT OF APPEALS )ss: NINTH JUDICIAL DISTRICT COUNTY OF MEDINA )

IN RE: JOSEPH CRIPPS C.A. No. 22CA0012-M

APPEAL FROM JUDGMENT ENTERED IN THE COURT OF COMMON PLEAS COUNTY OF MEDINA, OHIO CASE No. 21CIV0433

DECISION AND JOURNAL ENTRY

Dated: January 17, 2023

TEODOSIO, Presiding Judge.

{¶1} Appellant Joseph Cripps appeals from the judgment of the Medina County Court

of Common Pleas denying his petition for a certificate of qualification for employment (“CQE”).

This Court reverses and remands the matter for a new hearing.

I.

{¶2} On May 28, 2021, a petition for a CQE for Mr. Cripps was filed in the trial court.

The petition indicated that Mr. Cripps had two convictions from 2013 which disqualified him from

employment or licensing in an occupation. Notices were issued pursuant to R.C. 2953.25. See

R.C. 2953.25(B)(5)(b). The Medina County Prosecutor’s Office responded and indicated that it

did not recommend that Mr. Cripps receive a CQE as it believed that potential employers had a

right to know about his offenses. The Cuyahoga County Prosecutor’s Office expressed no opinion

about whether Mr. Cripps should receive a CQE but noted that Mr. Cripps had completed all court

ordered sentencing conditions and did not have any outstanding financial obligations. 2

{¶3} A magistrate thereafter requested that the Medina County Adult Probation

Department prepare a CQE Investigation Report outlining Mr. Cripps’ criminal history. While it

appears such a report was created and provided to the trial court, the report is not part of this

Court’s record. A hearing on the petition was held before a magistrate on September 15, 2021.

The magistrate issued a written decision denying Mr. Cripps’ petition. Mr. Cripps filed objections

to the decision. On January 4, 2022, the trial court issued a decision overruling the objections and

denying Mr. Cripps’ petition.

{¶4} Mr. Cripps has appealed, raising a single assignment of error for review.

II.

ASSIGNMENT OF ERROR

THE TRIAL COURT ERRED AS A MATTER OF BOTH LAW AND INTERPRETATION OF THE FACTS IN DENYING PETITIONER- APPELLANT’S OBJECTIONS TO THE MAGISTRATE’S DECISION DENYING HIS PETITION FOR A CERTIFICATE OF QUALIFICATION FOR EMPLOYMENT (CQE).

{¶5} Mr. Cripps argues in his assignment of error that the trial court erred in denying his

petition. Mr. Cripps argues that the trial court applied an incorrect version of the statute and that

it made erroneous findings concerning the statutory elements.

{¶6} Mr. Cripps’ petition was filed in May 2021 and the hearing on his petition took

place in September 2021, accordingly we will examine the version of the statute in effect during

that timeframe. R.C. 2953.25(C)(8) states that, “[i]f a court of common pleas that receives an

individual’s petition for a certificate of qualification for employment under division (B)(2) of this

section or that is forwarded a petition for such a certificate under division (B)(5)(a) of this section

denies the petition, the individual may appeal the decision to the court of appeals only if the 3

individual alleges that the denial was an abuse of discretion on the part of the court of common

pleas.”

{¶7} Here, the trial court first determined that Mr. Cripps, “[a]t [the] hearing and his

written petition,” “failed to designate a collateral sanction that he suffered as a result of his

conviction.” Then, the trial court examined the factors in R.C. 2953.25(C)(3) and found that Mr.

Cripps failed to satisfy them all.

{¶8} We agree with Mr. Cripps that the trial court utilized an incorrect version of the

statute in evaluating Mr. Cripps’ petition. This is evidenced by the language used in the trial

court’s entry.

{¶9} First, the trial court stated that, “[a]t [the] hearing and in his written petition, [Mr.]

Cripps has failed to designate a collateral sanction that he has suffered as a result of his conviction.”

It is true that R.C. 2953.25(B) states that only “[a]n individual who is subject to one or more

collateral sanctions as a result of being convicted of or pleading guilty to an offense” may file for

a CQE. See R.C. 2953.25(B)(1), (2). A collateral sanction is defined as “a penalty, disability, or

disadvantage that is related to employment or occupational licensing, however denominated, as a

result of the individual’s conviction of or plea of guilty to an offense and that applies by operation

of law in this state whether or not the penalty, disability, or disadvantage is included in the sentence

or judgment imposed.” R.C. 2953.25(A)(1). It does not include “imprisonment, probation, parole,

supervised release, forfeiture, restitution, fine, assessment, or costs of prosecution.” Id. This is

important as, “[a] certificate of qualification for employment issued to an individual lifts the

automatic bar of a collateral sanction, and a decision-maker shall consider on a case-by-case basis

whether to grant or deny the issuance or restoration of an occupational license or an employment

opportunity, notwithstanding the individual's possession of the certificate, without, however, 4

reconsidering or rejecting any finding made by a designee or court under division (C)(3) of this

section.” R.C. 2953.25(D)(1).

{¶10} While the definition of collateral sanction has not changed over the statute’s history,

the requirements of what must be included in the petition have. From the language used in the

trial court’s entry, it appears the trial court believed that Mr. Cripps had to identify in his petition

a collateral sanction. However, the version of the statute in effect at the time of Mr. Cripps’

petition did not include that requirement. See former R.C. 2953.25(F). Instead, only the versions

in effect prior to September 29, 2015 included a requirement that the petition include “[t]he name

or type of each collateral sanction from which the individual is requesting a certificate of

qualification for employment[.]” See former R.C. 2953.25(F)(5). Moreover, we note that R.C.

2953.25(C)(4) provides that “[t]he submission of an incomplete petition by an individual shall not

be grounds for the designee or court to deny the petition.” See also In re R.L.B., 9th Dist. Summit

No. 28765, 2018-Ohio-3660, ¶ 7-8.

{¶11} Later in the entry, the trial court examined the factors in R.C. 2953.25(C)(3);

however, in so doing, it quoted a version of the statute that was not in effect at the time of the

proceedings.

{¶12} The version of R.C. 2953.25(C)(3) in effect at the time states that,

[e]xcept as provided in division (C)(5) of this section and subject to division (C)(7) of this section, a court that receives an individual's petition for a certificate of qualification for employment under division (B)(2) of this section or that is forwarded a petition for such a certificate under division (B)(5)(a) of this section may issue a certificate of qualification for employment, at the court's discretion, if the court finds that the individual has established all of the following by a preponderance of the evidence:

(a) Granting the petition will materially assist the individual in obtaining employment or occupational licensing. 5

(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.

Free access — add to your briefcase to read the full text and ask questions with AI

Related

Hopkins v. Certificate of Qualification for Emp.
2025 Ohio 1072 (Ohio Court of Appeals, 2025)
In re Deran
2023 Ohio 2902 (Ohio Court of Appeals, 2023)

Cite This Page — Counsel Stack

Bluebook (online)
2023 Ohio 111, Counsel Stack Legal Research, https://law.counselstack.com/opinion/in-re-cripps-ohioctapp-2023.