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Name: In M.L.
Case #: E068050
Court: CA Court of Appeal
District 4 DCA
Division: 2
Opinion Date: 12/08/2017

Juvenile court’s denial of minor’s petition to seal public school records affirmed where court found it could not grant the request without first reviewing the records. The prosecution filed a petition (Welf. & Inst. Code, § 602) alleging the minor illegally possessed a knife at school. The minor completed a program of informal supervision (Welf. & Inst. Code, § 654) and the petition was dismissed. The minor unsuccessfully requested that the court seal his school records. The juvenile court found that because the minor did not present the records to the court, it could not determine whether a sealing order would protect the minor or others at the school. On appeal, the minor challenged the court’s requirement that he provide the documents to the court to support his request. Held: Affirmed. A trial court may grant a request to seal eligible records in the custody of a public agency if this will promote the successful reentry and rehabilitation of the individual (Welf. & Inst. Code, § 786). Education records, including student disciplinary records, are protected from disclosure under state and federal law, making it unclear why a court-ordered sealing of the records was necessary in this case. The only proffered reason for sealing the minor’s school records was that he would be applying for colleges soon. But he failed to show that the colleges would require all of his school records. In addition, it could be beneficial to the school to have access to information regarding the incident in this case in order to facilitate the minor’s rehabilitation and education and to protect other students. The juvenile court correctly found that more specific identification of the records to be sealed was required to adequately exercise its discretion.

The full opinion is available on the court’s website here: