State of Connecticut v. Lionel G. Dudley

Summary

The court held that the statutory erasure remedy for an offense later decriminalized does not extend to records of a probation-violation proceeding. A probation revocation proceeding is civil in nature, and the violation finding was supported by the defendant's underlying conduct and general admission, rather than by the later-erased conviction itself. The court also rejected reliance on the rule of lenity because the erasure statute is procedural and legislative history resolved any interpretive uncertainty.