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Christopher Woodhousev.The State

CourtCourt of Appeals of Georgia
Docket No.A16A0358
DecidedApril 20, 2016
Reporter246 Ga. App. 822
JudgesCourt of Appeals of Georgia
Tags
CriminalCriminal ProcedureStatutory InterpretationVacaturRemand
Case Summary

Christopher Woodhouse asked the trial court to seal clerk-of-court records relating to an earlier arrest under Georgia’s criminal-record-sealing statute. The trial court denied the motion without considering its merits, reasoning that the statutory provision did not apply to the pre-July 2013 arrest. The Court of Appeals held that the statute’s clear and unambiguous language expressly applies to arrests predating July 1, 2013, and therefore governs a request to seal the related court records. Because the trial court used an incorrect statutory interpretation and never reached the merits of Woodhouse’s request, the appellate court could not resolve the sealing question itself. It vacated the order and remanded for the trial court to consider the motion under the correct legal framework. The decision did not order the records sealed or determine whether Woodhouse ultimately qualifies for relief. Two judges concurred.

Opinion

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Christopher Woodhouse v. The State — The Atlanta Gleaner