LEVI M. RUFFIN v. UNITED STATES, 135 A.3d 799

In 2010 Ruffin was arrested after a 911 burglary report; police found him alone in an alley near the reported scene; he bumped into Officer Amaya and brushed the officer's hand away. He was tried and convicted of misdemeanor assault on a police officer (APO) and felony threats (to a police car); acquitted of first-degree burglary.
On direct appeal this court (Ruffin I) reversed the APO and felony-threats (property-directed) convictions as unsupported by law/evidence.
Ruffin moved the trial court to (1) seal arrest records, (2) obtain a certificate of innocence under D.C. Code § 2-422 and 28 U.S.C. § 2513, and (3) recover $250 paid into the Victim/Witness/VVC Fund. The trial court granted sealing (except for burglary), denied a certificate of innocence (concluding it lacked jurisdiction under § 2513), and denied reimbursement.
On appeal the D.C. Court of Appeals held the Superior Court does have authority to issue certificates of innocence under both D.C. law and § 2513 but nonetheless affirmed denial on the merits because Ruffin could not prove by clear and convincing evidence that he did not, by misconduct, cause or bring about his own prosecution.
The court remanded only to order return of the $250 VVC Fund payment, finding the trial court has authority and duty to correct the illegal assessment.

Issue	Ruffin's Argument	Government's Argument	Held
Whether Superior Court has jurisdiction to issue a certificate of innocence under D.C. § 2-422 and 28 U.S.C. § 2513	Superior Court can and should issue a certificate for unjust imprisonment	Although Superior Court can, Ruffin cannot meet the statutory merits	Court: Superior Court has jurisdiction to issue certificates under both statutes
Whether Ruffin is entitled to a certificate of innocence because his convictions were reversed	Reversal of APO and threats means he is entitled to certificate and to pursue damages	Reversal alone insufficient; must prove by clear and convincing evidence he did not, by misconduct, cause his prosecution	Court: Reversal satisfies first element but Ruffin failed the second (misconduct) element; certificate denied
Scope of “misconduct” that bars relief under unjust-imprisonment statutes	Argues a narrow Betts definition (must have misled authorities)	Advocates broader definition including conduct causally related to prosecution (Gates approach)	Court adopts broader Gates interpretation: misconduct includes wrongful conduct tied to the events that led to prosecution
Whether Ruffin is entitled to reimbursement of VVC Fund payment	Seeks return of $250 assessed as part of reversed convictions	Trial court said no authority; gov’t supports refund given illegal assessment	Court: Refund required; remands for trial court to order return of $250

Ruffin v. United States, 76 A.3d 845 (D.C. 2013) (direct appeal reversing APO and property-directed felony threats)
Betts v. United States, 10 F.3d 1278 (7th Cir. 1993) (narrow definition of "misconduct" for unjust-imprisonment relief)
Gates v. District of Columbia, 66 F. Supp. 3d 1 (D.D.C. 2014) (adopts broader definition of "misconduct" tied to conduct surrounding the charged offense)
Diamen v. United States, 604 F.3d 653 (D.C. Cir. 2010) (discusses certificate-of-innocence prerequisites for federal claims)
United States v. McRae, 580 F. Supp. 1560 (D.D.C. 1984) (criminal violations of D.C. Code are offenses against the United States)
Heath v. United States, 26 A.3d 266 (D.C. 2011) (standard for affirming without remand where record conclusively supports a single disposition)
Randolph v. United States, 882 A.2d 210 (D.C. 2005) (affirmance on other grounds permissible absent procedural unfairness)