State v. R.H.B.
2011 Minn. App. LEXIS 147
Minn. Ct. App.2011Background
- In May 2006, T.B., respondent RH B.'s wife, provided daycare for P., a friend's three-month-old, at their home.
- P. sustained head injuries including subdural hematoma and multiple fractures while in respondent's care.
- WCDHS found by preponderance that respondent placed P. in jeopardy, shook him, and lied to delay medical care; no appeal filed by respondent.
- Respondent was charged with third-degree assault—substantial bodily harm and later first-degree assault—great bodily harm; trial yielded acquittals on both counts.
- Respondent petitioned to expunge his arrest and related records; district court allowed live-testimony limitation and accepted affidavits opposing expungement.
- State appealed, arguing the district court abused its discretion by failing to balance statutory interests and by lacking stated reasons for expungement.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the district court abused its discretion in expunging records | State argues balancing the public interest over petitioner’s disadvantages supports expungement. | B. argues no stated statutory basis and no rehabilitation or compelling rationale; vague justification insufficient. | Abuse of discretion; reversed. |
Key Cases Cited
- State v. Ambaye, 616 N.W.2d 256 (Minn.2000) (statutory expungement standard and de novo review of legal questions)
- State v. K.M.M., 721 N.W.2d 330 (Minn.App.2006) (balancing public interest in expungement)
- State v. J.R.A., 714 N.W.2d 722 (Minn.App.2006) (distinguishes fact pattern on rehabilitative showing and grounds for expungement)