## Facts

- Four juveniles were arrested after a child alleged a sexual assault; delinquency petitions were filed alleging indecent liberties under state law.
- At the juvenile hearing, the complaining witness declined to testify with her father’s acquiescence, and the indecent-liberties petitions were dismissed.
- The juveniles had varying histories of prior arrests, ranging from one to thirteen arrests.
- After dismissal, the juveniles moved to expunge all related Seattle Police Department arrest records and juvenile court intake, social, and legal files.
- The juveniles argued that retaining and disseminating records tied to dismissed charges would stigmatize them and harm future educational and employment opportunities.
- The juvenile court denied the motion, and the juveniles sought review.

## Issues

1. Whether juveniles are entitled to complete expunction of police arrest records and juvenile court files when the delinquency petition is dismissed.
2. Whether juvenile arrest records may be released to prospective employers or nonrehabilitative educational institutions.

## Decision

- The court affirmed the denial of complete expunction of juvenile arrest records and juvenile court files.
- The court held that juvenile arrest records may not be released under any circumstances to prospective employers or nonrehabilitative educational institutions.
- The court treated controlled confidentiality, rather than destruction of records, as the proper means to reduce stigma while preserving the juvenile system’s functioning.

## Legal Principles

- The juvenile justice system is designed to protect, guide, and rehabilitate juveniles rather than punish them; recordkeeping supports individualized dispositions.
- Juvenile court personnel may require access to a juvenile’s background and prior contacts to evaluate causes of delinquency and determine appropriate supervision or services.
- Complete expunction of juvenile arrest and court records may be denied when it would impair rehabilitative decisionmaking within the juvenile system.
- Juvenile arrest records must be insulated from nonrehabilitative uses; disclosure to prospective employers and nonrehabilitative educational institutions is categorically prohibited.

## Conclusion

The court rejected a right to wholesale expungement of juvenile arrest and court records after dismissal of delinquency petitions, reasoning that retention serves the rehabilitative administration of juvenile justice, but it sharply limited collateral consequences by forbidding disclosure of juvenile arrest records to employers and nonrehabilitative schools.


Monroe v. Tielsch, 84 Wash. 2d 217, 525 P.2d 250 (Wash. 1974)