Fuller v. Delaware

Dana Fuller appealed a Family Court decision denying her petition for expungement of her juvenile record because she had committed three traffic violations as an adult. In this case, the Family Court held that Fuller's violations of Title 21, which governs motor vehicles, were "subsequent . . . adult convictions." But the Family Court has reached different conclusions in other cases as to whether a traffic violation under Title 21 of the Delaware Code is a subsequent adult conviction that precludes expungement of a juvenile record. On appeal, Fuller argued that Title 21 offenses were not "subsequent adult convictions" and the denial of her expungement was therefore erroneous. After review, the Supreme Court held that a "subsequent adult conviction” is a later conviction only for a crime in violation of Title 4, 7, 11, 16, or 23 of the Delaware Code, and does not include a violation of Title 21. Accordingly, we reverse the Family Court's decision. View "Fuller v. Delaware" on Justia Law