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Name: In re A.B. (2023) 94 Cal.App.5th 82
Case #: A165499
Court: CA Court of Appeal
District 1 DCA
Division: 5
Opinion Date: 08/03/2023

Welfare and Institutions Code section 781 does not bar supplemental petitions to seal juvenile records. In 2009, when A.B. was 13, he pleaded no contest to two charges, was declared a ward of the juvenile court, and was placed on probation, which ended in 2014. Eight years later, the juvenile court granted A.B.’s initial petition to seal his juvenile records under section 781. But when A.B. filed another petition, this time listing additional agencies that had access to his records yet were not listed in the initial petition or sealing order, the court denied the petition on the ground that it lacked the authority to grant a subsequent petition. A.B. appealed. Held: Reversed. Section 781 provides a procedure for sealing a person’s juvenile court records in the custody of the probation department, law enforcement agencies, and other agencies. Although the statute does not expressly state whether a supplemental or amended petition is permitted, the plain language of section 781 does not bar such a petition (when the first fails to seal all juvenile records). The juvenile court erred by ruling otherwise. Where “a rehabilitated juvenile offender is eligible for section 781 relief, no purpose is served by permanently barring them from correcting an omission in the initial petition.”