State v. T.S.N., 547 S.W.3d 617

In 2010 T.S.N. was charged with misdemeanor theft by check (warrant issued) and in 2013 she was arrested for aggravated assault; at the 2013 arrest the 2010 warrant was executed and she was booked on both charges (different courts/cause numbers).
T.S.N. pleaded guilty to the theft charge but was tried by jury on the assault charge and acquitted.
After acquittal she petitioned under TEX. CODE CRIM. PROC. art. 55.01(a)(1)(A) to expunge records "relating to the arrest" for the assault charge; the trial court granted relief and the court of appeals affirmed.
The State appealed, arguing the statute is "arrest-based" so an arrest that yields both a conviction and an acquittal precludes any expunction of arrest records arising from that arrest.
T.S.N. argued the statute is "offense-based" (at least under subsection (a)(1)(A)) so acquittal on the assault requires expunction of records relating to that offense notwithstanding the separate theft conviction.
The Court considered statutory text, structure (including subsection (c) addressing criminal episodes), practical concerns about partial expunction, and legislative intent to provide limited remedial relief.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether art. 55.01(a)(1)(A) requires expunction only when all offenses arising from a single arrest meet the statutory prereqs, or whether acquittal on an individual charged offense permits expunction of records relating to that offense even if another unrelated charge from the same arrest resulted in conviction	Article 55.01(a)(1)(A) is offense-based for acquittals; acquittal of the assault entitles T.S.N. to expunction of records relating to that assault charge only	Article 55.01 is arrest-based; an arrest producing multiple charges must have all charges meet expunction criteria (i.e., no conviction) for any arrest records to be expunged	The statute is not wholly arrest-based or wholly offense-based; under (a)(1)(A) acquittal of the specific offense entitles the petitioner to expunction of records relating to that offense (partial expunction allowed); affirmed

State v. Beam, 226 S.W.3d 392 (Tex. 2007) (expunction proceedings are civil in nature)
Harris Cty. Dist. Attorney's Office v. J.T.S., 807 S.W.2d 572 (Tex. 1991) (reading expunction text and effect of arrest-related records)
Texas Dep't of Pub. Safety v. G.B.E., 459 S.W.3d 622 (Tex. App.—Austin 2014, pet. denied) (multi-charge arrest where dismissal led to conviction on related offense; court declined to decide whether article 55.01(a)(2) is charge- or arrest-based)
In re Expunction, 465 S.W.3d 283 (Tex. App.—Houston [1st Dist.] 2015, no pet.) (court concluded article 55.01 applied to all charges stemming from an arrest)
Sommers for Ala. & Dunlavy, Ltd. v. Sandcastle Homes, Inc., 521 S.W.3d 749 (Tex. 2017) (statutory construction principle: analyze statutes as cohesive, contextual whole)
Jaster v. Comet II Constr., Inc., 438 S.W.3d 556 (Tex. 2014) (plain-meaning canon; avoid absurd results)