State v. R.H.B., 821 N.W.2d 817

R.H.B. was charged in 2007 with third- and first-degree assault but was acquitted by a November 2009 jury verdict; district court entered judgment of acquittal.
R.H.B. petitioned in January 2011 to seal all related records, seeking expungement under Minn. Stat. ch. 609A, §609A.02–03.
The district court granted expungement, applying a two-step framework: presumption of expungement if all proceedings resolved in petitioner’s favor, then a must-balance against public-interest evidence.
The State appealed, and the court of appeals reversed, finding no base to balance since no specific disadvantage to expungement was identified.
This Court reverses, holding the expungement statute’s first-step presumption applies and the State failed to overcome it with specific, clear-and-convincing public-interest evidence.
The case clarifies the standard and scope for expunging records after acquittal under Minn. Stat. 609A.02–03.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Interpretation of the expungement statute two-step process.	R.H.B. relies on step one presumption of expungement.	State argues must identify public-safety outweighs disadvantages.	Statutes create mandatory first step with presumption of expungement.
Whether the State proved by clear and convincing evidence to overcome the presumption.	State shows general public interest in keeping records.	State failed to show particularized harm or public-safety risk.	District court did not abuse discretion; State failed to show outweighing public interest.
Whether petition satisfied statutory content requirements in 609A.03, subd. 2.	Petition stated reasons tied to acquittal and interests of justice.	State contends insufficient specificity.	Petition satisfied the statutory requirement of stating reasons.
Appropriateness of the standard of review and balancing approach used.	District court abused discretion by misapplying standard.	Balancing is discretionary under 609A.03, subd. 5(b).	Abuse of discretion standard applied; no reversible error in balancing.

Ambaye v. State, 616 N.W.2d 256 (Minn. 2000) (establishes presumptive entitlement to expungement upon threshold showing; presumption rebuttable)
Humes, 581 N.W.2d 317 (Minn. 1998) (‘shall’ language is mandatory in expungement statute)
Ambaye (quoting), 616 N.W.2d 256 (Minn. 2000) (reiterates two-step expungement framework)
Am. Family Ins. Grp. v. Schroedl, 616 N.W.2d 273 (Minn. 2000) (discusses weighing public interests in expungement)
Jones, 753 N.W.2d 677 (Minn. 2008) (clear-and-convincing standard requires more than minimal evidence)