Ex Parte R.P.G.P., 623 S.W.3d 313

Petitioner R.P.G.P. was arrested after a traffic stop and charged with two misdemeanors: DWI (with BAC ≥ .15) and possession of a small amount of marijuana discovered in an inventory search.
DWI charge was dismissed after petitioner completed a pretrial intervention program; the possession charge resulted in nine months of deferred adjudication probation then dismissal (equivalent to court-ordered community supervision).
Petitioner sought expunction of the DWI arrest records under Tex. Code Crim. Proc. art. 55.01(a)(2)(A)(ii)(c).
The State opposed partial expunction, arguing that when an arrest involves multiple offenses expunction is arrest-based and unavailable unless all charges from the same arrest are eligible.
The trial court denied expunction after overruling petitioner's nondisclosure-based objection; the court of appeals affirmed.
The Texas Supreme Court reversed, holding Article 55.01(a)(2) (and its misdemeanor proviso) is offense-based for misdemeanors and permits partial expunction of eligible misdemeanor arrest records.

Issue	Petitioner's Argument	State's Argument	Held
Whether Article 55.01(a)(2) requires expunction to be arrest-based (all charges from the arrest must be eligible) or offense-based for misdemeanors (individual offenses may be expunged)	Article 55.01(a)(2) and the proviso use singular wording ("the charge/the offense," "a misdemeanor") and legislative edits ("any" → "the") show the statute ties expunction to an individual offense; T.S.N. supports partial expunction and redaction	Article 55.01 is arrest-focused (prefatory "all records and files relating to the arrest") so an arrest with multiple charges is all-or-nothing; relatedness or plea bargains linking charges prevent partial expunction	Held offense-based for misdemeanors: the prerequisites and the misdemeanor proviso in (a)(2) refer to an individual offense, permitting partial expunction of the DWI arrest records; reversed and remanded to grant expunction
Whether the trial court could compel testimony about the possession charge despite a nondisclosure order (i.e., whether nondisclosure barred inquiry in the expunction hearing)	Petitioner argued the nondisclosure order shielded him from being questioned about the possession charge	State contended the court could inquire into related charges when evaluating expunction eligibility	Court did not reach this alternative argument because it resolved the statutory-construction issue in petitioner's favor

State v. T.S.N., 547 S.W.3d 617 (Tex. 2018) (construed Article 55.01(a)(1) as offense-based and approved partial expunction/redaction for individual offenses)
Ex parte E.H., 602 S.W.3d 486 (Tex. 2020) (describing expunction as statutory, exclusive remedy and standard of review)
Ross v. St. Luke’s Episcopal Hosp., 462 S.W.3d 496 (Tex. 2015) (statutory interpretation starts with plain language read in context)
Entergy Gulf States, Inc. v. Summers, 282 S.W.3d 433 (Tex. 2009) (legislative deletions and changes in text can illuminate intent)