State v. J.B.

2025 Ohio 3143
CourtOhio Court of Appeals
DecidedSeptember 4, 2025
Docket114501
StatusPublished
Cited by2 cases

This text of 2025 Ohio 3143 (State v. J.B.) 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. J.B., 2025 Ohio 3143 (Ohio Ct. App. 2025).

Opinion

[Cite as State v. J.B., 2025-Ohio-3143.]

COURT OF APPEALS OF OHIO

EIGHTH APPELLATE DISTRICT COUNTY OF CUYAHOGA

STATE OF OHIO, :

Plaintiff- Appellee, : No. 114501 v. :

J.B., :

Defendant-Appellant. : _______________________________________

JOURNAL ENTRY AND OPINION

JUDGMENT: VACATED AND REMANDED RELEASED AND JOURNALIZED: September 4, 2025

Criminal Appeal from the Cuyahoga County Court of Common Pleas Case No. CR-21-662571-A

Appearances:

Michael C. O’Malley, Cuyahoga County Prosecuting Attorney, and Gregory J. Ochocki, Assistant Prosecuting Attorney, for appellee.

Cullen Sweeney, Cuyahoga County Public Defender, and Thomas T. Lampman, Assistant Public Defender, for appellant.

MICHELLE J. SHEEHAN, P.J.:

Defendant-appellant J.B. appeals from the trial court’s judgment entry

denying his application to expunge the criminal records in this case. Prior to denying his application, the trial court ordered J.B. to submit to a drug test and

conditioned its decision on the results of that test. Since the trial court did not have

the authority under the relevant sealing and expungement statutes to order J.B. to

submit to a drug test upon filing an application for expungement, we vacate the trial

court’s judgment denying J.B.’s application and remand this case back to the trial

court to proceed in a manner consistent with this opinion.

I. Procedural History and Relevant Facts

A. Background

On December 28, 2021, J.B. pleaded guilty to one count of carrying

concealed weapons, a misdemeanor of the first degree, and one count of receiving

stolen property, a misdemeanor of the first degree. He was sentenced the same day.

The trial court ordered J.B. to serve a one-year term of community-control

sanctions. J.B.’s term of community control was terminated on December 28, 2022.

B. Application for Expungement

On March 21, 2024, J.B. filed an application to expunge this case

pursuant to R.C. 2953.32(B). The trial court ordered an expungement report and

investigation to be completed by the probation department. The State responded to

J.B.’s application. The State advised the trial court that J.B.’s case was eligible for

expungement and deferred to the trial court.

On July 1, 2024, the court held a hearing on J.B.’s application, along

with multiple other applicants seeking to either expunge or seal their cases. The

judge issued the following advisement to all the applicants: So what I am going to explain to everybody is that, I will hear from everybody, hear their case, but I am going to send everybody down for a drug screen today. Okay? And so if I determine pending the drug screen that you’re eligible but you’re going to be precluded because you think that — you know that you’re going to come to test positive, I’m going to give you an opportunity to withdraw it now.

...

Because I don’t have you on active probation. I don’t know how you’ve been doing. I don’t know what you’ve been doing for the past years, and I can’t determine whether or not you’re fully rehabilitated.

An attorney for one of the applicants asked the judge if this

requirement applied even if the underlying offenses were unrelated to drug use. The

judge replied that it did. The judge explained that drug use contributes to crime and

that “if you’re testing positive for meth, you’re actively participating in illegal acts.”

Counsel for J.B. objected to the trial court’s order requiring J.B. submit

to a drug test. Counsel explained, “As a general rule, where it’s a broad policy, we

think that would be built into statute. And particularly as it applies to someone who

doesn’t have drug charges and that’s not what brought them here[.] Counsel’s

objection was overruled.

The trial court held a hearing on J.B.’s application. The State did not

object, leaving it to the trial court’s discretion. At the conclusion of the hearing the

judge stated:

Okay. So the same as I have with everybody else, pending the drug screen, pending passing the drug screen I’ll grant your petition. Okay?

On the same day, the trial court issued the following order, journalized

on the docket: Petition for expungement pending drug screen.

Petitioner ordered to be drug screened no later than 7/2/24, at State’s costs. Failure to do so will result in dismissal of petition.

On October 1, 2024, the trial court issued the following entry, denying

J.B.’s application for expungement:

Motion for expungement of criminal record $50, filed., [sic] filed 03/21/2024 is denied.

Court held hearing on motion and referred defendant for a drug screen. Defendant tested positive for amphetamines. Defendant’s EIR contains history of drug treatment, and later violations and ultimately termination. Defendant continued offending through the current case. This court cannot find that defendant is rehabilitated to the satisfaction of the court when still violating the law by consuming illegal drugs.

C. Appeal

J.B. filed a notice of appeal on the trial court’s entry denying his

application for expungement. On appeal, J.B. presents two assignments of error for

our review:

1. R.C. 2953.32 does not authorize trial courts to order all expungement applicants submit to warrantless post-hearing urine screens, or to deny applications based on such test.

2. The trial court’s blanket warrantless urine testing of expungement applicants violates the United States and Ohio Constitutions’ prohibitions on unreasonable searches.

II. Law and Analysis

A. First Assigned Error for Review

In his first assigned error for review, J.B. argues that R.C. 2953.32 does

not authorize the trial court to order an applicant for expungement to submit to a drug test and to base its decision on the results. Since there is nothing in the relevant

expungement and sealing statutes that authorizes the trial court to order an

applicant for an expungement to submit to a drug test upon filing an application for

expungement, we sustain J.B.’s first assigned error.

1. Standard of Review

As a condition for sealing and/or expungement of their criminal

records, the trial court has adopted a blanket policy requiring each applicant before

it to submit to a drug test. Generally, “[b]lanket policies that affect substantial rights

are not favored under the law and should not be employed. But when a court

implements a blanket policy, the appellate court reviews the application of that

policy under an abuse of discretion standard.” Cleveland v. Umstead,

2021-Ohio-10, ¶ 27 (8th Dist.) (Sheehan, J., dissenting), citing State v. Beasley,

2018-Ohio-16 (holding that the trial court abused its discretion in adopting a blanket

policy of not accepting no-contest pleas); State v. Switzer, 2010-Ohio-2473, ¶ 15

(8th Dist.) (holding that the trial court abused its discretion by adopting a policy of

not accepting plea agreements on the day of trial).

However, before we address whether the trial court abused its

discretion by adopting a broad blanket policy requiring all applicants submit to a

drug test, we must first determine whether a trial court has the authority to order

applicants to submit to drug testing in the first place.

The Supreme Court of Ohio has recognized that “‘it is the role of the

legislature to address the statutory scheme on sealing records[.]’” State v.

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Cite This Page — Counsel Stack

Bluebook (online)
2025 Ohio 3143, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-jb-ohioctapp-2025.