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Ohio Supreme Court rules against mandatory sealing of juvenile delinquency records

LEGAL NEWSLINE

Sunday, December 22, 2024

Ohio Supreme Court rules against mandatory sealing of juvenile delinquency records

State Supreme Court
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Chief Justice Sharon L. Kennedy | Ohio Supreme Court Website

A state law requiring the sealing of juvenile delinquency records when a juvenile is not found delinquent has been ruled unconstitutional by the Supreme Court of Ohio. The Court decided that this law violates the Ohio Constitution because it does not consider the public's interest in accessing these records.

The case arose from a 2022 trial presided over by Hamilton County Juvenile Court Judge Kari Bloom, where a juvenile was found not delinquent despite police testimony. Judge Bloom denied access to the trial transcript based on state law, prompting the Cincinnati Enquirer to seek legal intervention for access.

Justice R. Patrick DeWine, writing for the majority, stated that the law contravenes the "open courts provision" of the Ohio Constitution. He noted that previous court decisions had incorrectly equated this provision with First Amendment rights, arguing that they protect different rights.

"In adopting the open courts provision, the voters who enacted our Constitution made the decision that the administration of justice is best done in the open. We are obligated to honor their decisions by holding true to the text of our Constitution," he wrote.

Chief Justice Sharon L. Kennedy and Justice Patrick F. Fischer supported Justice DeWine’s opinion, along with Third District Court of Appeals Judge Juergen Waldick.

Justice Michael P. Donnelly concurred with finding the law unconstitutional but disagreed with overruling prior decisions to reach this conclusion. He argued that existing case reasoning suffices without overturning past rulings.

In dissent, Justice Melody Stewart contended that Judge Bloom adhered to current law when sealing records and emphasized that some court proceedings remain closed to protect confidentiality and rehabilitation interests in juvenile cases. Justice Jennifer Brunner joined her dissent.

The Supreme Court's analysis traced back historical contexts of open court provisions and concluded such rights must be balanced against public interest even in juvenile proceedings. It directed Judge Bloom to release the trial transcript since no juvenile interest remains due to J.L.'s death.

This ruling may have broader implications for how juvenile court proceedings are handled concerning public access and confidentiality across Ohio.

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