State v. Radcliff
Annotate this CaseThe Governor granted a pardon to Appellant that extended to five convictions that occurred in several counties, including a felony conviction in Franklin County. Appellant subsequently applied to the Franklin County Common Pleas Court for an order sealing his conviction in that forum. The trial court granted Appellant’s application to seal. The Tenth District Court of Appeals reversed, concluding that no statute authorized the sealing of Appellant’s record based on a gubernatorial pardon. Subsequently, the Tenth District certified its decision as in conflict with the First District’s decision in State v. Cope, which provides that a trial court may seal the record of a conviction that has been erased by a pardon. The Supreme Court recognized the conflict, accepted Appellant’s discretionary appeal, and consolidated the causes. The Court then resolved the conflict by rejecting Cope and affirming the decision of the Tenth District, holding that a court lacks the authority to seal a criminal record of a pardoned offender who does not meet applicable statutory requirements for sealing the record.
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