Ohio Court of Appeals reverses ruling on eviction record sealing

The Ohio Court of Appeals recently ruled in Dodd v. Preston (C.A. No. 2025-CA-42) that a lower court's decision to deny a tenant's request to seal eviction records was improper. The case centers around Cynthia Preston, who sought to seal her eviction records to improve her chances of securing housing. The court's ruling highlights the importance of balancing public access to court records with individual privacy rights.

This decision affects tenants in similar situations who may face barriers to housing due to public eviction records. The ruling emphasizes the need for courts to carefully consider the implications of such records on individuals' lives.

Background

The dispute began when David Dodd filed a forcible entry and detainer action against Cynthia Preston in the Miami County Municipal Court on September 19, 2023. The court granted Dodd restitution of the premises a month later, but by that time, Preston had already vacated the property, making the restitution issue moot.

On April 23, 2025, Preston filed a motion to seal or redact court documents related to her eviction. In her affidavit, she explained that the eviction record negatively impacted her ability to secure safe and affordable housing for her family. Despite her claims, the trial court denied her motion without providing any analysis, leading to Preston's appeal.

The Ruling

The Ohio Court of Appeals, led by Judge Robert G. Hanseman, reversed the trial court's decision. The court found that the lower court did not adequately consider the factors outlined in the Ohio Rules of Superintendence (Sup.R. 45) when denying Preston's request. The ruling stated, "The trial court failed to provide any analysis supporting its judgment. It did not apply the factors under Sup.R. 45(E) or weigh Preston’s interests against the presumption of openness of court records."

Furthermore, the court noted that the trial court did not consider less restrictive means, such as redacting the records instead of denying the motion outright. The appellate court emphasized that the presumption of public access to court records must be balanced against individual privacy interests.

Impact

This ruling has significant implications for tenants facing eviction records and their ability to find housing. By reversing the trial court's decision, the Ohio Court of Appeals reinforced the need for courts to consider the impact of public records on individuals' lives. This case sets a precedent that could influence how similar cases are handled in the future.

The court's decision emphasizes the importance of providing a clear rationale when denying motions to seal or redact records. This clarity is essential for ensuring that individuals have the opportunity for meaningful appellate review, particularly in cases involving sensitive information that could affect their livelihoods.

What's Next

The case has been remanded to the trial court for further proceedings. The trial court is now required to provide a detailed explanation of its reasoning for denying Preston's motion to seal or redact the eviction records. This ruling can potentially be appealed further, depending on the outcome of the trial court's subsequent decisions.