Toledo v. Hair

2023 Ohio 1415
CourtOhio Court of Appeals
DecidedApril 28, 2023
DocketL-22-1122
StatusPublished

This text of 2023 Ohio 1415 (Toledo v. Hair) 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
Toledo v. Hair, 2023 Ohio 1415 (Ohio Ct. App. 2023).

Opinion

[Cite as Toledo v. Hair, 2023-Ohio-1415.]

IN THE COURT OF APPEALS OF OHIO SIXTH APPELLATE DISTRICT LUCAS COUNTY

City of Toledo Court of Appeals No. L-22-1122

Appellee Trial Court No. TRC-18-17788

v.

Christopher Hair DECISION AND JUDGMENT

Appellant Decided: April 28, 2023

*****

Rebecca Facey, City of Toledo Chief Prosecuting Attorney, and Jimmie L. Jones, Assistant Prosecuting Attorney, for appellee.

Anthony J. Richardson, II., for appellant.

DUHART, P.J.

{¶ 1} Appellant, Christopher Hair, appeals from a March 18, 2022 judgment

entered by the Toledo Municipal Court, denying his motion to seal the record in this case.

For the reasons that follow, we affirm the judgment of the trial court. Statement of the Case and Relevant Facts

Trial Court Proceedings

{¶ 2} On August 6, 2018, Hair was charged, in case No. TRC-18-1788, with OVI

and with failure to reinstate his license. Appellant refused to submit to a breath test and,

as a result, his license was placed under an ALS pursuant to R.C. 4511.191(B)(1).

{¶ 3} On February 4, 2020, the OVI charge was dismissed, and Hair entered a plea

of no contest to the charge of failure to reinstate his license. Despite the OVI charge

having been dismissed, the trial court ordered that the ALS would continue.

{¶ 4} On February 18, 2020, Hair, pro se, filed motion to seal the record in this

case and to terminate the ALS. On April 15, 2020, Hair filed a subsequent motion, listing

charges from previous traffic cases that he also wished to have sealed. Among the cases

listed were case Nos. TRD-13-37604, TRD-15-18029, TRC-15-38331, and TRD-16-

22309. In each case, the motion to seal was denied without a hearing.

{¶ 5} On July 23, 2020, the trial court denied Hair’s motion to seal the record in

case No. TRC-18-1788 without hearing. In a consolidated appeal filed on November 9,

2020, Hair appealed both the trial court’s decision to continue the ALS and the trial

court’s decisions not to seal appellant’s dismissed traffic offenses.

Appeals Court Proceedings

{¶ 6} On June 25, 2021, this court affirmed the trial court’s continuation of the

ALS in case No. TRC-18-1788, but reversed its denial of the motion to seal, holding that

Hair was entitled to a hearing in all of the previous traffic cases. See State v. Hair, 6th

2. Dist. Lucas No. L-20-1142, L-20-1143, L-20-1144, 2021-Ohio-2136, ¶ 25. The case was

then remanded back to the trial court. See id.

Proceedings Following Remand to the Trial Court

{¶ 7} On December 14, 2021, the trial court, on remand, conducted a hearing on

Hair’s motion to seal charges in case No. TRC-18-1788. At the hearing, Hair, appeared

pro se and, speaking on his own behalf, represented to the court that he is a sergeant in

the army and that he began his service in 2007. He asserted, without elaboration, that

sealing his records would benefit his military career. He further stated that sealing his

records would be of use to him when, after he attends law school, he applies to take the

bar exam. He explained that he had been accepted into law school at the University of

Toledo but was deferring his enrollment due to a pending 400-day deployment to Kuwait.

{¶ 8} When the trial court asked Hair whether he had any pending criminal cases

against him, he answered, “Currently, right now I do. * * * The pending charge is in – it’s

a Menacing charge in Common Pleas.” He also admitted to having a “currently” pending

OVI.

{¶ 9} Next, the trial court heard from the state. Arguing against the sealing of

Hair’s records, the state asserted that the public has a right to “observe how OVI cases

are worked out in the state of Ohio,” and that the availability of such information

“keep[s] judges, prosecutors, and public servants accountable.” The state further argued

that there is no way to seal Hair’s cases without also ordering the Bureau of Motor

Vehicles to seal its records, and that such an order would hinder the Bureau’s ability to

3. properly enforce any future ALS suspensions that might be imposed against Hair. In

making this argument, the state pointed out that, at the time of the hearing, Hair had four

previous OVI allegations against him in the last ten years. Upon further questioning by

the trial court, the state conceded that only one of the past OVI allegations led to a

conviction, and that the conviction was for a reduced charge of reckless operation.

Finally, the state addressed Hair’s interest in having his record sealed, commenting that

even if the record were sealed, Hair would still have to disclose the charges in connection

with his bar exam character and fitness evaluation, thereby negating any claimed benefit.

{¶ 10} After hearing from Hair and from the state, the trial court took the matter

under advisement.

Trial Court Decision

{¶ 11} In a written decision, issued after the hearing, the trial court denied Hair’s

motion to seal on two grounds. First, the trial court found that the motion was not timely,

because at the time Hair presented the motion, he had two criminal cases pending: (1)

TRC-21-09669, which was an OVI case pending in the Toledo Municipal Court; and (2)

CR-2020-01671, which was an “F4” pending in the Lucas County Court of Common

Pleas. Second, the trial court concluded that “the Petitioners [sic] interests do not

outweigh the State’s interest in maintaining the records.”

{¶ 12} It is from this decision that Hair currently appeals.

4. Assignment of Error

{¶ 13} Appellant raises the following assignment of error on appeal:

I. The trial court abused its discretion to the prejudice of appellant by

denying his motion to seal his criminal record.

Analysis

{¶ 14} Under R.C. 2953.52(A)(1), “[a]ny person * * * who is the defendant named

in a dismissed complaint * * * may apply to the court for an order to seal the person’s

official records in the case.” Upon the filing of an application, the court must set a date

for the hearing and must notify the prosecutor. R.C. 2953.52(B)(1). The prosecutor may

object to the granting of the application by filing with the court, prior to the date set for

the hearing, an objection specifying the reasons that would justify a denial of the

application Id. The court must then: (1) determine whether the complaint was dismissed

with prejudice; (2) determine whether criminal proceedings are pending against the

person; (3) consider the prosecutor’s reasons for objection; and (4) weigh the interests of

the person in having the records sealed against the government’s legitimate needs, if any,

to maintain those records. R.C. 2953.52(B)(2)(a)-(d). “If the court determines * * * that

the complaint * * * was dismissed * * *; that no criminal proceedings are pending against

the person; and [that] the interests of the person in having the records pertaining to the

case sealed 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

5. the case be sealed and that * * * the proceedings be deemed not to have occurred.” R.C.

2953.52(B)(4).

{¶ 15} “The sealing of a criminal record has been characterized as an ‘act of grace

created by the state.’” State v. T.D., 6th Dist. Lucas No. L-20-1149, 2021-Ohio-513, ¶ 15,

citing State v.

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Bluebook (online)
2023 Ohio 1415, Counsel Stack Legal Research, https://law.counselstack.com/opinion/toledo-v-hair-ohioctapp-2023.