Cornette v. State

CourtSupreme Court of Delaware
DecidedFebruary 5, 2026
Docket505, 2024
StatusPublished

This text of Cornette v. State (Cornette v. State) is published on Counsel Stack Legal Research, covering Supreme Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Cornette v. State, (Del. 2026).

Opinion

IN THE SUPREME COURT OF THE STATE OF DELAWARE

JOSEPH CORNETTE, § § Petitioner Below, § No. 505, 2024 Appellant, § § Court Below: Superior Court v. § of the State of Delaware § STATE OF DELAWARE, § C.A. No. 23X-00807 § Respondent Below, § Appellee. §

Submitted: November 19, 2025 Decided: February 5, 2026

Before SEITZ, Chief Justice; VALIHURA, TRAYNOR, LEGROW, and GRIFFITHS, Justices, constituting the Court en banc.

Upon appeal from the Superior Court of the State of Delaware. REVERSED and REMANDED.

John P. Deckers, Esquire (argued), Nicole Walker, Esquire, and Alanna R. Farber, Esquire, DELAWARE OFFICE OF DEFENSE SERVICES, Wilmington, Delaware, for Appellant Joseph Cornette.

Jordan A. Braunsberg, Esquire, DELAWARE DEPARTMENT OF JUSTICE, Wilmington, Delaware, for Appellee State of Delaware.

Richard A. Forsten, Esquire (argued), and Michelle Streifthau-Livizos, Esquire, SAUL EWING LLP, Wilmington, Delaware, for Amicus Curiae.

LEGROW, Justice: More than thirty years ago, Joseph Cornette pleaded guilty to assault and

Driving Under the Influence (“DUI”) after he collided with another vehicle while

driving drunk. Upon receiving an unconditional gubernatorial pardon of his assault

conviction, Cornette petitioned the Superior Court for discretionary expungement of

his pardoned conviction. The trial court denied his petition because the pardoned

conviction was joined with a “non-expungable” DUI conviction, and the court

interpreted Delaware law as requiring all charges in a case to be eligible for

expungement before a petition may be granted.

This appeal requires us to determine whether a pardoned conviction is eligible

for discretionary expungement under 11 Del. C. § 4375 even if the other charges in

the case are not eligible to be expunged. We hold that the statute permits a partial

expungement and that Cornette’s pardoned conviction therefore is eligible for

expungement. If the trial court exercises its discretion to expunge the conviction, it

may issue a partial expungement order limited to records pertaining to the expunged

charge. For the reasons set forth below, we REVERSE the trial court’s judgment

and REMAND for further proceedings consistent with this opinion.

I. RELEVANT FACTUAL AND PROCEDURAL BACKGROUND In 1993, twenty-one-year-old Joseph Cornette drove drunk, fell asleep while

driving, and caused a head-on collision with another vehicle. Cornette suffered

minor injuries, but the other driver was severely injured.

1 The State initially charged Cornette with Vehicular Assault Second Degree

and two Title 21 offenses, DUI and Improper Lane Change.1 The State later

dismissed the initial charges and obtained a new indictment that upgraded the

Vehicular Assault charge to Vehicular Assault First Degree, added one count of

Assault Second Degree, and retained the DUI and Improper Lane Change charges.2

Cornette pleaded guilty to Assault Second Degree and DUI in exchange for the State

entering a nolle prosequi on the remaining charges.3 Cornette served his sentence

and satisfied all payment obligations. Since the case was closed in 1996, Cornette

has faced no arrests, charges, or convictions.

In March 2022, Cornette applied for a governor’s pardon of his Assault

Second Degree conviction, which the State did not oppose.4 Nine months later, then-

Governor Carney granted Cornette’s pardon.5

The Adult Expungement Reform Act governs the mandatory and

discretionary expungement of criminal records. The Act explains that:

“Expungement” means that all law-enforcement agency records and court records relating to a case in which an expungement is granted, including any electronic records, are destroyed, segregated, or placed in the custody of the State Bureau of Identification, and are not released

1 Appellant’s Opening Br. at 5. 2 Id.; App. to Opening Br. at A1 (Super. Dkt.). 3 App. to Opening Br. at A2 (Super. Dkt. at D.I. 6 and 7). 4 Id. at A7–21 (Pardon Application). 5 Id. at A22–24 (Governor’s Pardon).

2 in conjunction with any inquiry beyond those specifically authorized under this subchapter.6 The statute defines “case” as “a charge or set of charges related to a complaint or

incident that are or could be properly joined for prosecution.”7

Section 4373 governs mandatory expungements, and Sections 4374 and 4375

cover discretionary expungements, creating alternative paths for expungement

eligibility. Section 4375 allows an individual to apply for discretionary

expungement following a pardon. Subsection (a) states:

Notwithstanding any provision of this subchapter or any other law to the contrary, a person who was convicted of a crime, other than those specifically excluded under subsection (b) of this section, who is thereafter unconditionally pardoned by the Governor may request a discretionary expungement under the procedures under § 4374(c) through (h) and (j) of this title.8 Subsection (b) lists specific convictions that “are not eligible for expungement after

a pardon under this section.”9

Section 4375 does not refer to pardons or expungements in terms of a “case.”

Instead, the section uses the term “crime,” which is undefined in the Act but defined

6 11 Del. C. § 4372(c)(4). 7 Id. § 4372(c)(1); Osgood v. State, 310 A.3d 415, 421 n.43 (Del. 2023) (“We also note that Section 4372(c) defines ‘Case’ and ‘Conviction’ broadly, and ‘Expungement’ applies to ‘all law- enforcement agency records and court records relating to a case in which an expungement is granted.’”). 8 11 Del. C. § 4375(a). 9 Id. § 4375(b).

3 in Title 11’s general provisions as an “act or omission forbidden by a statute of this

State and punishable upon conviction . . . .”10

A petitioner for discretionary expungement must file their petition in the

Superior Court and serve the Attorney General with a copy of the petition, along

with a certified copy of their criminal history as maintained by the State Bureau of

Identification (“SBI”).11 After the petition is filed, Subsection 4374(f) gives the

Superior Court discretion to grant or deny expungement, stating in relevant part:

If the Court finds that the continued existence and possible dissemination of information relating to the arrest or conviction of the petitioner causes, or may cause, circumstances which constitute a manifest injustice to the petitioner, it shall enter an order requiring the expungement of the law-enforcement and court records relating to the charge or case. Otherwise, it shall deny the petition. The burden is on the petitioner to allege specific facts in support of that petitioner’s allegation of manifest injustice, and the burden is on the petitioner to prove such manifest injustice by a preponderance of the evidence.12 If the petition is denied, the petitioner has a right to appeal.13

In May 2023, SBI sent Cornette a letter informing him that “a portion of [his]

certified criminal history” was eligible for mandatory expungement, and that his

pardoned conviction could be eligible for discretionary expungement.14 The letter

10 Id. § 4375; see also id. § 233(a). 11 Id. § 4374(e). 12 Id. § 4374(f). 13 Id. § 4374(g). 14 App. to Opening Br. at A28 (SBI Expungement Eligibility Letter).

4 attached a copy of Cornette’s certified criminal history, which listed the two nolle

prossed vehicular assault charges and the pardoned assault second conviction.15 The

criminal history did not contain the nolle prossed improper lane change charge or

Cornette’s DUI conviction, though the DUI conviction still appeared on the Superior

Court docket.16

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Cornette v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/cornette-v-state-del-2026.