Chelsey Ferguson v. Mississippi Department of Public Safety-Criminal

CourtMississippi Supreme Court
DecidedSeptember 26, 2019
Docket2017-CT-00912-SCT
StatusPublished

This text of Chelsey Ferguson v. Mississippi Department of Public Safety-Criminal (Chelsey Ferguson v. Mississippi Department of Public Safety-Criminal) is published on Counsel Stack Legal Research, covering Mississippi Supreme Court primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Chelsey Ferguson v. Mississippi Department of Public Safety-Criminal, (Mich. 2019).

Opinion

IN THE SUPREME COURT OF MISSISSIPPI

NO. 2017-CT-00912-SCT

CHELSEY FERGUSON

v.

MISSISSIPPI DEPARTMENT OF PUBLIC SAFETY

ON WRIT OF CERTIORARI

DATE OF JUDGMENT: 03/03/2017 TRIAL JUDGE: HON. ISADORE W. PATRICK, JR. TRIAL COURT ATTORNEYS: PAUL E. ROGERS NIKKI MARTINSON BOLAND COURT FROM WHICH APPEALED: WARREN COUNTY CIRCUIT COURT ATTORNEY FOR APPELLANT: PAUL E. ROGERS ATTORNEYS FOR APPELLEE: LORA E. HUNTER ANTHONY L. SCHMIDT NATURE OF THE CASE: CIVIL - OTHER DISPOSITION: THE JUDGMENT OF THE COURT OF APPEALS IS REVERSED, AND THE JUDGMENT OF THE WARREN COUNTY CIRCUIT COURT IS REINSTATED AND AFFIRMED - 09/26/2019 MOTION FOR REHEARING FILED: MANDATE ISSUED:

EN BANC.

CHAMBERLIN, JUSTICE, FOR THE COURT:

¶1. We granted the petition of the Mississippi Department of Public Safety (MDPS) for

certiorari review of the Court of Appeals’ decision that Chelsey Ferguson need no longer

register under the Mississippi Sex Offenders Registration Law (the Act) due to the

expungement of her misdemeanor sex offense. Ferguson v. Miss. Dep’t of Pub. Safety, No. 2017-CA-00912-COA, 2018 WL 4572805, at *3–4 (Miss. Ct. App. Sept. 25, 2018). Because

Mississippi Code Section 45-33-55 (Rev. 2015) exempts sex offenses from orders of

expungement to the extent that the information concerning those offenses is authorized for

dissemination under the Act, we reverse the Court of Appeals’ decision and reinstate the

circuit court’s judgment.

FACTS AND PROCEDURAL HISTORY1

¶2. In 2011, Ferguson pleaded guilty to the misdemeanor offense of disseminating

sexually oriented material to a minor. Miss. Code Ann. § 97-5-27 (Rev. 2006). As a result

of her conviction, Ferguson had to register as a sex offender. Miss. Code Ann. § 45-33-25

(Rev. 2015).

¶3. Approximately five years later, she filed a successful expungement petition.2 After

the expungement, MDPS sent Ferguson’s attorney an “Expunction Resolution Notice,”

stating that it could not process the expungement order because “ANY CONVICTION FOR

A SEX OFFENSE EXEMPTS AN EXPUNGEMENT UNDER THE 1ST OFFENDER

STATUTE.” Thus, MDPS refused Ferguson’s request for relief from her obligation to

register as a sex offender.

¶4. In response, Ferguson filed a complaint against MDPS, seeking to be relieved from

her duty to register under the Act. The circuit court denied Ferguson’s request.

1 Much of the facts and procedural history of this case are adapted from the Court of Appeals’ opinion. Ferguson, 2018 WL 4572805, at *1. 2 We note that the validity of the expungement itself is not before the Court today.

2 ¶5. Aggrieved, Ferguson appealed. After the close of briefing, we assigned the case to

the Court of Appeals. Ferguson raised two assignments of error. First, she argued that

MDPS had no authority to challenge her request for relief from the obligation to register.

Second, she maintained that the circuit court erred by finding that she still had to register

despite her expungement. We limit our review of the Court of Appeals’ decision to the

second issue. M.R.A.P. 17(h).

¶6. Addressing that issue, the Court of Appeals reversed the circuit court and held that

Ferguson no longer had to register as a sex offender. Ferguson, 2018 WL 4572805, at *3–4.

It based its reasoning on Stallworth v. State, 160 So. 3d 1161 (Miss. 2015), in which the

Court held that under Mississippi law a party had no duty to register under the Act when the

party’s sex-offense conviction had been expunged in a foreign jurisdiction. Id. Stallworth,

though, dealt with a foreign sex-offense conviction that also had been expunged in the

foreign jurisdiction. Because Section 45-33-55 exempts sex offenses from the laws of this

state or court orders authorizing expunging criminal-history records “to the extent such

information is authorized for dissemination under” the Act, we reverse the Court of Appeals’

decision and reinstate the ruling of the circuit court.

ANALYSIS

¶7. “Expungement is a creature of statute.” Stallworth, 160 So. 3d at 1168 (Pierce, J.,

dissenting) (citing Hentz v. State, 152 So. 3d 1139, 1140 (Miss. 2014); Caldwell v. State,

564 So. 2d 1371, 1373 (Miss. 1990) (recognizing that a court’s power to expunge is granted

3 by statute)). Further, “expungement . . . is an act of legislative grace.” Polk v. State, 150 So.

3d 967, 968 (Miss. 2014) (citing Caldwell, 564 So.2d at 1372–73). “No common law right

to the expungement of criminal records exists.” Polk v. State, 150 So. 3d 967, 968 (Miss.

2014) (citing In re Expungement Application of G.P.B., 91 A.3d 648, 649 (N.J. Super. Ct.

App. Div. 2014)). “Expungement from official records [of] all records relating to an arrest,

indictment, trial, and finding of guilt, in order to restore one to the status occupied prior

thereto, is an altruistic objective for the legislative branch to contemplate and prescribe.” Id.

at 970. It is axiomatic that, if expungements are a matter of Legislative grace, then the

Legislature can limit their applicability or effect. This is what the Legislature has done in

Section 45-33-55.

¶8. Mississippi Code Section 99-19-71(1) provides that “[a]ny person who has been

convicted of a misdemeanor that is not a traffic violation, and who is a first offender, may

petition the justice, county, circuit or municipal court in which the conviction was had for an

order to expunge any such conviction from all public records.” Miss. Code. Ann. §

99-19-71(1) (Rev. 2015). As noted above, the validity of Ferguson’s expungement is not

before us. Nevertheless, the Legislature has exempted sex offenses (other than certain

juvenile matters) from orders of expungement to the extent that the information concerning

those offenses is authorized for dissemination under the Act.3 This exemption is codified in

3 Felony sex offenses may not be expunged under Mississippi law. As expungement is a creature of statute, there must be statutory authority for any expungement. Section 99- 19-71 does not give any court the authority to expunge any felony sexual offenses. Miss.

4 Section 45-33-55 which reads,

Except for juvenile criminal history information that has been sealed by order of the court, this chapter exempts sex offenses from laws of this state or court orders authorizing the destroying, expunging, purging or sealing of criminal history records to the extent such information is authorized for dissemination under this chapter.

Miss. Code. Ann. § 45-33-55. The exemption is in line with the Legislature’s declaration of

purpose for the Act, which reads, in part, “that releasing such information about criminal sex

offenders to the general public will further the primary governmental interest of protecting

vulnerable populations and, in some instances the public, from potential harm.” Miss. Code

Ann. § 45-33-21 (Rev. 2015).

¶9.

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Related

Caldwell v. State
564 So. 2d 1371 (Mississippi Supreme Court, 1990)
In the Matter of the Expungement of the Criminal Records of G.P.B.
91 A.3d 648 (New Jersey Superior Court App Division, 2014)
Zachary Polk v. State of Mississippi
150 So. 3d 967 (Mississippi Supreme Court, 2014)
Rebecca Hentz v. State of Mississippi
152 So. 3d 1139 (Mississippi Supreme Court, 2014)
Jeffery A. Stallworth v. State of Mississippi
160 So. 3d 1161 (Mississippi Supreme Court, 2015)

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Chelsey Ferguson v. Mississippi Department of Public Safety-Criminal, Counsel Stack Legal Research, https://law.counselstack.com/opinion/chelsey-ferguson-v-mississippi-department-of-public-safety-criminal-miss-2019.