State v. Dye

Pursuant to Ohio Rev. Code 2953.52(B)(4), a trial court may seal the records in a case dismissed without prejudice before the statute of limitations has expired.Here, the State filed a complaint against Defendant charging him with arson, among other crimes. The State later dismissed the complaint without prejudice. Defendant filed an application to seal the official records of the case pursuant to section 2953.52. The trial court denied the application on the grounds that the case had been dismissed without prejudice and the statute of limitations had not yet expired. The court of appeals affirmed. The Supreme Court reversed, holding that section 2953.52 does not require the relevant statute of limitations to expire before a trial court can grant an application to seal the records of a case dismissed without prejudice. View "State v. Dye" on Justia Law