Dodd v. Preston

Citations

• 2026 Ohio 1887

Syllabus

After a forcible entry and detainer action was determined, appellant filed a motion to seal and/or redact the court records of the proceeding pursuant to Sup.R. 45(E). The trial court overruled appellant's motion without analysis. A direct appeal is the remedy for a party aggrieved by a trial court's failure to grant relief under Sup.R. 45(E). A de novo standard of review applies in evaluating a trial court's decision on relief under Sup.R. 45(E), but when a trial court does not provide any basis for its decision, as in this case, remand is necessary for the trial court to provide its reasoning and enable subsequent appellate review. Judgment reversed and remanded.