State v. H.M.

Citations

• 2025 Ohio 5522

Syllabus

Expungement; sealing; restitution; final discharge; cognovit note; eligible offender; rehabilitation. The judgment granting the defendant's motion to seal or expunge is vacated. Although the Ohio Supreme Court Client Security Fund paid the victim the amount of restitution the trial court ordered the defendant to pay, the defendant has not fully reimbursed the Fund as ordered. The defendant signed a cognovit note for the amount of his remaining balance owed to the victim, but a cognovit note is not payment in full sufficient to constitute final discharge for the purpose of sealing or expunging a conviction. Further, the defendant failed to present testimony or evidence that the other statutory requirements for sealing or expungement were met.