State v. Tysinger

2026 Ohio 199
CourtOhio Court of Appeals
DecidedJanuary 22, 2026
DocketCT2025-0067
StatusPublished

This text of 2026 Ohio 199 (State v. Tysinger) 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. Tysinger, 2026 Ohio 199 (Ohio Ct. App. 2026).

Opinion

[Cite as State v. Tysinger, 2026-Ohio-199.]

COURT OF APPEALS MUSKINGUM COUNTY, OHIO FIFTH APPELLATE DISTRICT

STATE OF OHIO Case No. CT2025-0067

Plaintiff - Appellee Opinion And Judgment Entry

-vs- Appeal from the Court of Common Pleas, Case No. CR2024-0695 JARED G. TYSINGER Judgment: Affirmed Defendant – Appellant Date of Judgment Entry: January 22, 2026

BEFORE: Andrew J. King; William B. Hoffman; David M. Gormley, Appellate Judges

APPEARANCES: JOSEPH A. PALMER, for Plaintiff-Appellee; SCOTT P. WOOD, for Defendant-Appellant.

King, P.J.

{¶ 1} Defendant-Appellant, Jared G. Tysinger, appeals the June 24, 2025

judgment entry of the Muskingum County Court of Common Pleas denying his application

to seal records. Plaintiff-Appellee is the State of Ohio. We affirm the trial court.

FACTS AND PROCEDURAL HISTORY

{¶ 2} On October 30, 2024, the Muskingum County Grand Jury indicted Tysinger

on two counts of gross sexual imposition in violation of R.C. 2907.05. A jury trial

commenced on April 8, 2025. The jury found Tysinger not guilty of both charges.

{¶ 3} On April 24, 2025, Tysinger filed an application to seal/expunge records of

the charges under R.C. 2953.33; the prosecutor filed an objection. A hearing was held

on June 23, 2025. The trial court denied the application, finding the state's interest in keeping the records open outweighed Tysinger's interest in sealing them. The trial court

journalized its denial in a judgment entry filed June 24, 2025.

{¶ 4} Tysinger filed an appeal with the following assignment of error:

I

{¶ 5} "THE TRIAL COURT ABUSED ITS DISCRETION BY DENYING

APPELLANT'S APPLICATION TO SEAL RECORDS AFTER A NOT GUILTY VERDICT

BY A JURY."

{¶ 6} In his sole assignment of error, Tysinger claims the trial court abused its

discretion in denying his application to seal his records after a not guilty finding. We

disagree.

{¶ 7} Our standard of review in this case is whether the trial court abused its

discretion. State v. Calderon, 2010-Ohio-2807, ¶ 6 (9th Dist.), citing State v. Singer,

2009-Ohio-909, ¶ 5 (9th Dist.) ("If the matter in dispute concerns the court's discretion,

such as its conclusion that the evidence does not weigh in favor of expungement, then

an abuse of discretion standard applies"); accord State v. Brown, 2025-Ohio-2018, ¶ 10

(5th Dist.). "Abuse of discretion" means an attitude that is unreasonable, arbitrary or

unconscionable. Huffman v. Hair Surgeon, Inc., 19 Ohio St.3d 83, 87 (1985). Most

instances of abuse of discretion will result in decisions that are simply unreasonable,

rather than decisions that are unconscionable or arbitrary. AAAA Enterprises, Inc. v.

River Place Community Urban Redevelopment Corp., 50 Ohio St.3d 157, 161 (1990). An

unreasonable decision is one backed by no sound reasoning process which would

support that decision. Id. "It is not enough that the reviewing court, were it deciding the issue de novo, would not have found that reasoning process to be persuasive, perhaps

in view of countervailing reasoning processes that would support a contrary result." Id.

We note the sealing/expungement of criminal records "is a privilege, not a right." State

v. Moore, 2012-Ohio-4483, ¶ 16 (5th Dist.).

{¶ 8} Under R.C. 2953.33(A)(1), "[a]ny person, who is found not guilty of an

offense by a jury or a court . . . may apply to the court for an order to seal or . . . expunge

the person's official records in the case." Tysinger filed his application without any

reasons other than he was found not guilty of the charges, he did not have any criminal

charges currently pending against him, and his interest in sealing the records was not

outweighed by any legitimate governmental interest in keeping the records open. The

prosecutor filed an objection, arguing the following:

The State's interests in maintaining the record in this case greatly

outweighs any interest applicant may assert. Should defendant face

charges in the future, the records would provide the Court and law

enforcement agencies with valuable information. It is well established that

when an applicant is sentenced, courts can consider offenses that have not

resulted in a conviction or charge because courts should have "the fullest

information possible concerning the applicant's life and characteristics."

These records are essential in the functioning of the judicial system

because the records provide a thorough history of applicant's contact with

the criminal justice system, thereby allowing the court to understand the

applicant's history. (Citations omitted.) Finally, the public has a legitimate interest in examining criminal

records. As more and more businesses are concerned about the safety and

security of their employees, criminal records checks allow employers to

determine whether a prospective employee has had contact with the

criminal justice system. . . . By maintaining legitimate public access to the

record, future employers would at least be able to question applicant about

the case and the facts underlying the charges.

{¶ 9} Under R.C. 2953.33(B)(2)(c), the trial court shall "consider the reasons

against granting the application specified by the prosecutor in the objection." The trial

court shall also "[w]eigh the interests of the person in having the official records pertaining

to the case sealed or expunged, as applicable, against the legitimate needs, if any, of the

government to maintain those records." R.C. 2953.33(B)(2)(e). Under subsection (B)(4):

If the court determines, after complying with division (B)(2) of this

section, that the person was found not guilty in the case . . . ; that no criminal

proceedings are pending against the person; and the interests of the person

in having the records pertaining to the case sealed or expunged, as

applicable, are not outweighed by any legitimate governmental needs to

maintain such records, . . . the court shall issue an order directing that all

official records pertaining to the case be sealed or expunged, as applicable,

and that, except as provided in section 2953.34 of the Revised Code, the

proceedings in the case be deemed not to have occurred. {¶ 10} During the hearing, Tysinger argued four reasons for having his records

sealed:

{¶ 11} 1) Although he is employed, he is concerned if that employment should

terminate, the charges could prejudice his application in the future.

{¶ 12} 2) He is worried he could have similar consequences for potential attempts

to gain housing in the future.

{¶ 13} 3) He is interested in having an active role in his children's lives and the

charges could prejudice him in future custody matters.

{¶ 14} 4) He would like to take an active role in his children's extracurriculars, like

being a coach, and the charges could affect his chances to do so. June 23, 2025 T. at 4.

{¶ 15} The prosecutor reiterated the arguments contained in the filed written

objection (Id. at 5):

In the motion that the State put - - or the memorandum in opposition,

the government interest here would be, you know, if there ever came a

future day where there was future criminal, civil issues, this information

provides insight as to the underlying records which law enforcement relies

on, the type of conduct that that Court or that tribunal could find interesting

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Related

State v. Moore
2012 Ohio 4483 (Ohio Court of Appeals, 2012)
State v. Stringer, 08ca0038-M (3-2-2009)
2009 Ohio 909 (Ohio Court of Appeals, 2009)
Huffman v. Hair Surgeon, Inc.
482 N.E.2d 1248 (Ohio Supreme Court, 1985)
State v. Brown
2025 Ohio 2018 (Ohio Court of Appeals, 2025)

Cite This Page — Counsel Stack

Bluebook (online)
2026 Ohio 199, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-tysinger-ohioctapp-2026.