In re I.F., A146979

Background

I.F. committed juvenile offenses in 2012–2014, was declared a ward, placed on probation, and had multiple subsequent petitions; probation terminated successfully on December 3, 2014 and juvenile petitions were dismissed.
I.F. filed to seal his juvenile records on November 3, 2014 under former Welf. & Inst. Code § 781.
Effective January 1, 2015, the Legislature enacted former § 786, which mandates automatic sealing after satisfactory completion of probation for offenses not listed in § 707(b).
While I.F.’s sealing petition remained pending, he was charged as an adult in April 2015; the prosecutor sought disclosure of certain juvenile records for impeachment under § 827.
The juvenile court denied I.F.’s § 781 sealing petition (finding rehabilitation not shown) and granted limited disclosure for impeachment; I.F. appealed.
The Court of Appeal reversed and remanded, holding the juvenile court should have applied § 786 in adjudicating the pending sealing petition and the related disclosure request.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Which statute governs a sealing petition filed before but decided after § 786 took effect?	Forfeiture: defendant didn’t raise § 786 below; court should not consider it on appeal.	§ 786 applies prospectively to pending petitions adjudicated after Jan 1, 2015; it eliminates the rehabilitation showing and mandates sealing.	Court exercised discretion to reach the argument and held § 786 governed the adjudication because it is procedural and prospective for pending matters.
Does application of § 786 to a pending petition operate retroactively?	People: presumption against retroactivity; new law shouldn’t change rights for past conduct.	§ 786 is procedural/amendatory, does not impose new liabilities, so its application to pending matters is prospective.	Court held application was prospective (not impermissibly retroactive) because § 786 changed sealing procedure, not legal consequences of past conduct.
Was denying sealing under former § 781 proper given factual record?	Probation dept. and court found rehabilitation not attained; denial affirmed.	Even under § 781, record insufficient to deny; also counsel failures and DA delays affected process.	Court did not resolve these factual/ineffective-assistance claims because statutory-error resolution (applying § 786) required reversal and remand.
Was disclosure for impeachment permissible after sealing denial?	Prosecutor sought limited disclosure for impeachment under § 827; court granted contingent disclosure.	Disclosure was tied to sealing outcome and should be revisited if § 786 requires sealing.	Court reversed the disclosure order and remanded for reconsideration under § 786.

Key Cases Cited

Californians for Disability Rights v. Mervyn’s LLC, 39 Cal.4th 223 (2006) (explains prospective vs. retroactive application of statutes and that procedural rules governing pending litigation may be applied prospectively)
In re Y.A., 246 Cal.App.4th 523 (2016) (interpreting § 786’s automatic-sealing mandate after satisfactory probation)
People v. Estrada, 63 Cal.2d 740 (1965) (rule on retroactive application of ameliorative criminal statutes)
People v. Brown, 54 Cal.4th 314 (2012) (limits Estrada to statutes that mitigate punishment)
Matteo v. Department of Motor Vehicles, 209 Cal.App.4th 624 (2012) (applying amended statute to post-enactment proceedings that affect pending cases without altering past legal consequences)