State v. Frye

2026 Ohio 647
CourtOhio Court of Appeals
DecidedFebruary 25, 2026
Docket31625
StatusPublished

This text of 2026 Ohio 647 (State v. Frye) 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. Frye, 2026 Ohio 647 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Frye, 2026-Ohio-647.]

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

CITY OF BARBERTON C.A. No. 31625

Appellee

v. APPEAL FROM JUDGMENT ENTERED IN THE MORGAN FRYE BARBERTON MUNICIPAL COURT COUNTY OF SUMMIT, OHIO Appellant CASE No. 13 CRB 1760

DECISION AND JOURNAL ENTRY

Dated: February 25, 2026

FLAGG LANZINGER, Presiding Judge.

{¶1} Defendant-Appellant, Morgan Frye, appeals the judgment of the Barberton

Municipal Court denying his application to seal his record. This Court affirms.

I.

{¶2} In January 2014, Frye entered a plea of no contest to one count of criminal

trespassing and one count of criminal damaging. In exchange for his plea, the State moved to

dismiss one count of assault. The trial court accepted Frye’s plea, dismissed the assault charge,

and found Frye guilty of both criminal trespassing and criminal damaging.

{¶3} In April 2025, Frye filed an application to seal the record of conviction. The trial

court held a hearing on Frye’s application on June 17, 2025. The State objected to Frye’s

application on the basis that Frye had two subsequent convictions for domestic violence and a

conviction for a reduced charge from an initial domestic violence complaint. Both domestic

violence charges occurred in 2018 and the conviction to the reduced charge occurred in 2021. The 2

nature of the reduced charge is unclear from the record. At the end of the hearing, the trial court

took the matter under advisement. In an order filed later that same day, the trial court denied

Frye’s application for sealing.

{¶4} Frye appeals, raising one assignment of error.

II.

ASSIGNMENT OF ERROR

THE TRIAL COURT ERRED IN DENYING FRYE’S EXPUNGEMENT APPLICATION.

{¶5} In his sole assignment error, Frye contends the trial court erred in denying his

application for sealing because (1) the trial court failed to comply with R.C. 2953.32, and (2)

applied the wrong legal standard when weighing Frye’s interest in having his criminal record

sealed against the State’s interest in maintaining the record. For the following reasons, we overrule

Frye’s assignment of error.

{¶6} “Depending on the dispute in question, this Court will apply either a de novo

standard of review or an abuse of discretion standard of review in appeals from the denial of an

application to seal a record of conviction.” State v. Calderon, 2010-Ohio-2807, ¶ 6 (9th Dist.).

This Court employs a de novo standard of review if the dispute involves the interpretation of the

sealing statutes. Stow v. S.B., 2015-Ohio-4473, ¶ 6 (9th Dist.). However, if the matter in dispute

concerns the trial court’s discretion, such as balancing the applicant’s and the government’s

interests in having the record of conviction sealed, then an abuse of discretion standard applies.

Calderon at ¶ 6. An abuse of discretion is something more than an error of law or in the exercise

of judgment; “it implies that the court’s attitude is unreasonable, arbitrary or unconscionable.”

Blakemore v. Blakemore, 5 Ohio St.3d 217, 219 (1983). When considering whether a trial court 3

abused its discretion, an appellate court is precluded from simply substituting its judgment for that

of the trial court. Pons v. Ohio State Med. Bd., 66 Ohio St.3d 619, 621 (1993).

{¶7} “The sealing of a criminal record . . . is an ‘act of grace created by the state.’”

(Internal citation omitted.) State v. Boykin, 2013-Ohio-4582, ¶ 11, quoting State v. Hamilton, 75

Ohio St.3d 636, 639 (1996). “It should be granted only when all requirements for eligibility are

met, because it is a ‘privilege, not a right.’” Boykin at ¶ 11, quoting State v. Futrall, 2009-Ohio-

5590, ¶ 6.

{¶8} R.C. 2953.32 governs the sealing of a criminal record after a conviction. “Upon

the filing of the application, the trial court must set the matter for a hearing, notify the prosecutor

of the hearing, and direct the probation department to ‘make inquiries and written reports’

regarding the applicant.” State v. A.V., 2019-Ohio-1037, ¶ 8 (9th Dist.), citing R.C. 2953.32(B).

Sealing proceedings are non-adversarial. Hamilton at 640; see State v. Simon, 87 Ohio St.3d 531,

533 (2000). “The primary purpose of a sealing hearing is the gathering of information in order to

provide the trial court with all the relevant information regarding the applicant’s compliance with

the sealing criteria.” A.V. at ¶ 8, citing Hamilton at 640; Simon at 533. R.C. 2953.32(D)(1) sets

forth specific matters the trial court must consider. Relevant to this appeal, a trial court must do

each of the following at the hearing:

(c) Determine whether the applicant has been rehabilitated to the satisfaction of the court;

(d) If the prosecutor has filed an objection in accordance with division (C) of this section, consider the reasons against granting the application specified by the prosecutor in the objection;

(e) If the victim objected, pursuant to the Ohio Constitution, consider the reasons against granting the application specified by the victim in the objection; 4

(f) Weigh the interests of the applicant in having the records pertaining to the applicant's conviction or bail forfeiture sealed or expunged against the legitimate needs, if any, of the government to maintain those records;

(g) Consider the oral or written statement of any victim, victim's representative, and victim's attorney, if applicable[.]

R.C. 2953.32(D)(1)(c)-(g).

{¶9} R.C. 2953.32(D)(2) provides for an applicant to have his record of conviction

sealed if the trial court finds (1) the applicant is an eligible offender, (2) the applicant has no

criminal proceedings pending against him, (3) the applicant’s interest in having his record sealed

are not outweighed by any legitimate governmental need to maintain the record of conviction, and

(4) the applicant has been rehabilitated to the satisfaction of the trial court. This Court has long

recognized that a trial court is not required to provide detailed reasoning when ruling on

applications filed pursuant to R.C. 2953.32. State v. N.C., 2024-Ohio-4739, ¶ 11, 15 (9th Dist.),

citing State v. Stringer, 2009-Ohio-909, ¶ 5 (9th Dist.). Rather, “[t]he trial court only needed to

‘provide sufficient information in its decision to enable a reviewing court to ascertain whether it

[had] considered all matters that must be evaluated and whether it [had] applied the correct tests

under the statute.’” (Emphasis in original.) N.C. at ¶ 15, quoting State v. N.C., 2022-Ohio-781, ¶

11 (9th Dist.).

{¶10} On appeal, Frye first contends the trial court erred because it failed to determine

whether Frye had been rehabilitated to the trial court’s satisfaction. Frye’s argument has no merit.

{¶11} A review of the record shows the trial court never expressly stated “Frye has not

been rehabilitated to the trial court’s satisfaction.” However, the trial court’s order denying his

application provides sufficient information to show the trial court considered whether Frye had

been rehabilitated to its satisfaction and that the trial court found he had not been so rehabilitated.

The trial court noted that the State objected to the sealing of Frye’s criminal record based on his 5

subsequent criminal convictions. The trial court then expressly stated that it was “especially

concerned” with Frye’s domestic violence convictions and indicated a preference for additional

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Related

State v. Boykin
2013 Ohio 4582 (Ohio Supreme Court, 2013)
State v. Futrall
2009 Ohio 5590 (Ohio Supreme Court, 2009)
Stow v. S.B.
2015 Ohio 4473 (Ohio Court of Appeals, 2015)
State v. Stringer, 08ca0038-M (3-2-2009)
2009 Ohio 909 (Ohio Court of Appeals, 2009)
State v. A.V.
2019 Ohio 1037 (Ohio Court of Appeals, 2019)
State v. N.C.
2022 Ohio 781 (Ohio Court of Appeals, 2022)
Blakemore v. Blakemore
450 N.E.2d 1140 (Ohio Supreme Court, 1983)
Pons v. Ohio State Medical Board
614 N.E.2d 748 (Ohio Supreme Court, 1993)
State v. Simon
721 N.E.2d 1041 (Ohio Supreme Court, 2000)
State v. N.C.
2024 Ohio 4739 (Ohio Court of Appeals, 2024)

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Bluebook (online)
2026 Ohio 647, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-frye-ohioctapp-2026.