On Tuesday, October 22, 2024, the Ohio Supreme Court granted writs of mandamus and prohibition in the case of State ex rel. Cincinnati Enquirer v. Bloom, addressing the issue of juvenile court record sealing. The ruling challenges existing state laws that mandate the sealing of juvenile delinquency records without a case-by-case analysis of public interest.
The court’s decision stems from a case involving a Hamilton County juvenile court judge, Kari L. Bloom, who sealed the records of a trial for a thirteen-year-old juvenile, J.L., accused of felonious assault. Judge Bloom dismissed the charges against J.L., which led to the sealing of the case records under Ohio Revised Code § 2151.356. The Cincinnati Enquirer sought access to these records following J.L.’s death in a subsequent shooting, arguing that the blanket sealing of records violates the Ohio Constitution’s open courts provision.
The Supreme Court’s ruling emphasized that the Ohio Constitution guarantees that “all courts shall be open,” highlighting the public’s right to attend court proceedings and access related records. The court found that the existing statute requiring the automatic sealing of records in juvenile cases does not allow for an individualized assessment of the potential harm from disclosure versus the benefits of public access.
The ruling overturned previous judicial interpretations that juvenile court proceedings were not subject to public access rights under the Ohio Constitution.
The court acknowledged a historical precedent in Ohio that has viewed the open courts provision as a fundamental right of citizens to observe the justice system. This provision has been part of Ohio’s Constitution since its inception, tracing its roots to early American legal frameworks emphasizing transparency in judicial proceedings.
The case arose when the Enquirer requested access to the transcripts of J.L.’s trial after his death. Judge Bloom denied this request, citing the sealing statute, without conducting a hearing. The Enquirer challenged the constitutionality of R.C. 2151.356, arguing that it conflicts with the open courts provision that requires a balancing of interests before sealing records.
The Supreme Court’s opinion clarified that while the right to access court records is not absolute, any attempt to restrict this access must be justified by a compelling interest. The court stated that the existing law’s blanket approach to sealing juvenile records fails to consider the important public interest in transparency and accountability within the judicial system.
In its decision, the court noted that historical interpretations of the open courts provision have included a right to access both live proceedings and the documentation of those proceedings. The court also pointed out that although juvenile court proceedings have traditionally been viewed as confidential to protect the welfare of minors, this confidentiality must be balanced against the public’s right to know.
A copy of the original filing can be found here.
