State v. Cain

2024 Ohio 2969, 249 N.E.3d 811
CourtOhio Court of Appeals
DecidedAugust 5, 2024
DocketCA2023-11-016
StatusPublished
Cited by1 cases

This text of 2024 Ohio 2969 (State v. Cain) 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
State v. Cain, 2024 Ohio 2969, 249 N.E.3d 811 (Ohio Ct. App. 2024).

Opinion

[Cite as State v. Cain, 2024-Ohio-2969.]

IN THE COURT OF APPEALS

TWELFTH APPELLATE DISTRICT OF OHIO

MADISON COUNTY

STATE OF OHIO, :

Appellee, : CASE NO. CA2023-11-016

: OPINION - vs - 8/5/2024 :

CHRISTOPHER W. CAIN, :

Appellant. :

CRIMINAL APPEAL FROM MADISON COUNTY COURT OF COMMON PLEAS Case No. 2000CR-05-030

Nick Adkins, Madison County Prosecuting Attorney, and Rachel M. Price and Michael S. Klamo, Assistant Prosecuting Attorneys, for appellee.

Joan Sahl, for appellee.

M. POWELL, J.

{¶ 1} Appellant, Christopher Cain, appeals a decision of the Madison County

Court of Common Pleas denying his application to seal his pardoned conviction.1

{¶ 2} Appellant was indicted in May 2000 for aggravated arson in violation of R.C.

1. We are disappointed and dismayed by the state's choice not to attend oral arguments. Madison CA2023-11-016

2909.02(A)(2). He subsequently pled no contest to one count of third-degree felony

attempted aggravated arson and the trial court found him guilty on September 20, 2000.

On June 8, 2021, Ohio Governor Mike DeWine granted appellant an unconditional pardon

for his attempted aggravated arson conviction.

{¶ 3} On August 18, 2023, appellant filed an application to seal his pardoned

conviction pursuant to R.C. 2953.33(A)(3). The state filed an objection to the sealing of

the record, and a hearing was held on appellant's application. On October 25, 2023, the

trial court denied appellant's application to seal his pardoned conviction. In doing so, the

trial court relied upon R.C. 2953.32(A)(1)(b), which provides that "[R.C.] 2953.32 to

2953.34 do not apply to . . . [c]onvictions of a felony offense of violence that is not a

sexually oriented offense." Because attempted aggravated arson is an offense of

violence under R.C. 2901.01(A)(9)(a) and (d) and is not a sexually oriented offense, the

trial court reasoned that appellant was not entitled to seal his pardoned conviction under

R.C. 2953.33.

{¶ 4} Appellant now appeals, raising one assignment of error:

{¶ 5} THE TRIAL COURT ERRED BY DENYING MR. CAIN'S MOTION TO SEAL

HIS PARDONED CONVICTION.

{¶ 6} The sealing of court records in a criminal case is an act of grace created by

the state. State v. Boykin, 2013-Ohio-4582, ¶ 11. It should be granted only when all the

requirements for eligibility are met, because it is a privilege, not a right. Id.

{¶ 7} As relevant to this appeal, two statutes govern the sealing of court records

in criminal cases: R.C 2953.32 governs the sealing of an individual's court records of a

criminal conviction; RC 2953.33 governs the sealing of the court records of an individual

who has been found not guilty, who had a criminal complaint, indictment, or information

dismissed, against whom a grand jury has returned a no bill, and since April 4, 2023,

-2- Madison CA2023-11-016

whose conviction has been pardoned.

{¶ 8} Prior to 2023, R.C. 2953.31 through 2953.38 governed the sealing of court

records of a criminal conviction. R.C. 2953.36 provided that "sections 2953.31 to 2953.35

of the Revised Code do not apply to any of the following" and then listed the convictions

that precluded sealing. One such conviction was one for an offense of violence. See

former R.C. 2953.36(A)(4). In turn, R.C. 2953.52 governed the sealing of court records

after a not guilty finding, a dismissal of proceedings, or a no bill by a grand jury. R.C.

2953.52 was located in a separate subchapter. The exclusions of R.C. 2953.36 clearly

did not apply to R.C. 2953.52.

{¶ 9} In April 2023, the legislature amended the Ohio Sealing Law in R.C. Chapter

2953. The legislature modified and reorganized the preexisting statutory provisions

regarding the sealing of court records of criminal convictions and the sealing of court

records after a not guilty finding, a dismissal of proceedings, or a no bill by a grand jury.

The legislature also added a provision allowing the sealing of an individual's court records

when the individual is convicted of an offense and subsequently receives a pardon.2

{¶ 10} R.C. 2953.32 continues to govern the sealing of court records of criminal

convictions. However, the statutory provision prohibiting specific convictions from being

sealed was relocated from R.C. 2953.36 to R.C. 2953.32(A). Likewise, the statutory

provision governing the sealing of court records after a not guilty finding, a dismissal of

proceedings, or a no bill by a grand jury was renumbered from R.C. 2953.52 to R.C.

2953.33, with the addition of a provision allowing the sealing of pardoned convictions in

R.C. 2953.33(A)(3).

2. In HB100, effective September 30, 2021, the legislature enacted R.C. 2967.04(C) which allows the governor, in the case of an unconditional pardon, to provide for the sealing of the records related to the conviction as a condition of the pardon. R.C. 2967.04(C) does not apply to appellant because he was pardoned before September 2021. -3- Madison CA2023-11-016

{¶ 11} As was the case before 2023, a trial court must hold a hearing on a sealing

application, must determine under either R.C. 2953.32 or 2953.33 if the prosecutor filed

an objection to a sealing application and, if so, must consider the prosecutor's objections.

R.C. 2953.32(C) and 2953.33(B). Under both statutory provisions, the court must also

weigh the applicant's interests in having the records sealed against the legitimate needs,

if any, of the government to maintain the records. R.C. 2953.32(D) and 2953.33(B).

{¶ 12} This appeal deals with the intersection of R.C. 2953.32(A)(1)(b) and

2953.33(A)(3). R.C. 2953.32(A)(1)(b) provides, "Sections 2953.32 to 2953.34 of the

Revised Code do not apply to . . . [c]onvictions of a felony offense of violence that is not

a sexually oriented offense." R.C. 2953.33(A)(3) provides,

Any person who is granted by the governor under division (B) of section 2967.02 of the Revised Code an absolute and entire pardon, a partial pardon, or a pardon upon conditions precedent or subsequent may apply to the court for an order to seal the person’s official records in the case in which the person was convicted of the offense for which any of those types of pardons are granted. The application may be filed at any time after an absolute and entire pardon or a partial pardon is granted or at any time after all of the conditions precedent or subsequent to the pardon are met.

{¶ 13} The effect of a governor's pardon is a significant aspect of construing the

interplay of R.C. 2953.32(A)(1)(b) and 2953.33(A)(3). R.C. 2967.04(B) provides that "[a]n

unconditional pardon relieves the person to whom it is granted of all disabilities arising

out of the conviction or convictions from which it is granted." "[A]lthough a pardon grants

the recipient relief from any ongoing punishment for the offense and prevents any future

legal disability based on that offense, it does not erase the past conduct. In other words,

what's done is done." Boykin, 2013-Ohio-4582 at ¶ 27. Thus, a pardoned conviction

retains its character as a conviction for purposes of the sealing statutes.

{¶ 14} Appellant argues the trial court erred by denying his application to seal his

-4- Madison CA2023-11-016

pardoned conviction on the basis of R.C. 2953.32(A)(1)(b) because the sealing of the

records of a pardoned conviction under R.C.

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Related

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2024 Ohio 4955 (Ohio Court of Appeals, 2024)

Cite This Page — Counsel Stack

Bluebook (online)
2024 Ohio 2969, 249 N.E.3d 811, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-cain-ohioctapp-2024.