Dana Fuller, Defendant-Below, Appellant v. State of Delaware, Plaintiff-Below, Appellee

Summary

The Court reversed the Family Court’s denial of Dana Fuller’s petition for discretionary expungement of her juvenile record. It held that the phrase “subsequent adult conviction” in the juvenile expungement statute refers only to later convictions for crimes under Titles 4, 7, 11, 16, or 23, and therefore does not include Title 21 traffic violations. The Court reasoned from the statute’s text, structure, application process, and stated purpose of protecting people from the consequences of juvenile arrest records. Justice Valihura, joined by Judge Davis, dissented, concluding that the statute’s plain language includes Title 21 violations and that any harshness must be corrected by the General Assembly.