The Ohio Supreme Court ruled on August 19, 2026, in the case of State ex rel. King v. Lyons, denying a request for access to sealed court records. The decision affects Kristen J. King, who sought the documents for a wrongful-death lawsuit against Austin Combs. The court found that there was no evidence the trial court had failed to follow the law when it sealed the records.
This case began when Kristen King, the administrator of Anthony King's estate, filed a mandamus action seeking access to sealed documents related to three criminal cases involving Combs. King argued that the trial court did not comply with statutory and constitutional requirements when it sealed the records. The sealed cases included a 2014 misdemeanor domestic violence charge, a 2015 misdemeanor theft and assault conviction, and a 2017 misdemeanor assault conviction.
The sealing orders were issued by Judge Robert H. Lyons of the Butler County Area I Court. King claimed that the trial court did not follow the Rules of Superintendence for the Courts of Ohio and that it improperly restricted access to the case documents. The court had previously denied a motion to dismiss from Judge Lyons and the other respondents, allowing the case to proceed.
In its ruling, the Ohio Supreme Court stated that the sealing orders were final judgments and could only be challenged if they were void due to a lack of subject-matter jurisdiction or if there were grounds set forth in the Civil Rules. The court noted that it has allowed challenges to sealing orders through mandamus actions when there is evidence that a trial court failed to follow the law. However, in this case, the court found no such evidence.
The court ruled, "Because nothing in the record demonstrates that the trial court failed to comply with the law when it issued the sealing orders, we deny the writ of mandamus." Judge Patrick DeWine authored the opinion, which was joined by Justices Jennifer Brunner, Melody J. Stewart, and Michael P. Donnelly. Chief Justice Maureen O'Connor joined the opinion except for one part, while Justices Sharon L. Kennedy and Pat Fischer dissented.
The court explained that King needed to show a clear legal right to the sealed records, a clear duty on the part of the court to unseal them, and that there was no adequate remedy available in the ordinary course of law. The court emphasized that a presumption of regularity attaches to all judicial proceedings, meaning that the trial court's actions are assumed to be valid unless proven otherwise.
In her arguments, King claimed that the trial court did not conduct a proper review of the sealed items and that there was no evidence of a hearing or that the prosecutor was notified. However, the court found that the sealed records showed that a hearing had been set and that the prosecutor was involved in the sealing process.
Furthermore, King raised constitutional arguments, claiming that the sealing orders violated the public's right to access court records under the First Amendment and the Ohio Constitution. The court stated that there was no evidence that the trial court failed to perform the necessary balancing of interests required by law. The court noted that the applicable sealing statutes required the trial court to weigh the privacy interests of the offender against the public's right to access court proceedings.
The Ohio Supreme Court concluded that King failed to demonstrate her entitlement to a writ of mandamus, thus denying her request for access to the sealed records. This ruling reinforces the importance of following statutory guidelines when sealing court records and highlights the challenges faced by individuals seeking access to such documents.
Looking ahead, this ruling may set a precedent for similar cases involving sealed court records in Ohio. It underscores the necessity for individuals seeking access to sealed documents to provide clear evidence that a trial court did not comply with the law. While King has the option to appeal the decision, the court's ruling stands as a significant barrier to accessing sealed records in this instance.