New Jersey Division of Child Protection and Permanency v. A.P.

CourtSupreme Court of New Jersey
DecidedJuly 31, 2024
DocketA-14-23
StatusPublished

This text of New Jersey Division of Child Protection and Permanency v. A.P. (New Jersey Division of Child Protection and Permanency v. A.P.) is published on Counsel Stack Legal Research, covering Supreme Court of New Jersey primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
New Jersey Division of Child Protection and Permanency v. A.P., (N.J. 2024).

Opinion

SYLLABUS

This syllabus is not part of the Court’s opinion. It has been prepared by the Office of the Clerk for the convenience of the reader. It has been neither reviewed nor approved by the Court and may not summarize all portions of the opinion.

New Jersey Division of Child Protection & Permanency v. A.P. (A-14-23) (088329)

Argued February 26, 2024 -- Decided July 31, 2024

PATTERSON, J., writing for a unanimous Court.

In this appeal, the Court considers whether the Division of Child Protection and Permanency (Division) met the requirements of N.J.S.A. 2C:52-19, an exception to New Jersey’s expungement statute, and was therefore properly authorized to use the expunged records of A.P. (Arlo), who was the subject of a criminal investigation that arose from serious injuries sustained by his son D.P. (Daniel), at a Title 9 abuse and neglect factfinding trial with the same subject matter.

In March 2019, emergency personnel were dispatched to Arlo’s home, where they encountered Arlo, his girlfriend, T.C. (Tiffany), and his two-year-old son, Daniel, who was unresponsive. Daniel was transported to a hospital, where he underwent emergency surgery. Arlo stated that Daniel had tripped over something in the kitchen, fallen on his face, and scraped his lip. Tiffany stated that the child did not appear to have sustained any other injuries but that she later found him with his eyes rolled back in his head and his body limp, prompting her to call 9-1-1.

A nurse at the hospital referred the matter to the Division, and the Division contacted the Monmouth County Prosecutor’s Office. The Division learned that Daniel had sustained a skull fracture and subdural hemorrhage, both of which were inconsistent with the tripping and falling incident Arlo and Tiffany described. The Division conducted an emergency removal of Daniel from Arlo’s custody and took custody of the child. The trial court upheld the Division’s removal of Daniel.

Arlo was arrested and charged with endangering the welfare of a child. The Division filed a Title 9 action seeking custody, care, and supervision of Daniel. In January 2022, a grand jury declined to indict Arlo, and his criminal records were subsequently expunged. In the Title 9 proceeding, the Division filed a motion to use the records of Arlo’s criminal proceedings pursuant to N.J.S.A. 2C:52-19. The trial court found “good cause and a compelling need to permit the release of records to the Division, the experts and the lawyers for all parties” in accordance with N.J.S.A. 2C:52-19. It noted that the Title 9 factfinding trial would be confidential, thus limiting the disclosure of expunged records. 1 The Appellate Division affirmed the trial court’s determination. 475 N.J. Super. 472, 482-92 (App. Div. 2023). The Appellate Division construed N.J.S.A. 2C:52-19 to require a trial court to “consider[] on a case-by-case basis” the question whether there is “compelling need based on specific facts and good cause shown.” Id. at 486. It found that standard to be met in this case. Ibid. The Court granted leave to appeal. 255 N.J. 426 (2023).

HELD: The Court concurs with the trial court and Appellate Division that the Division met the requirements of N.J.S.A. 2C:52-19 in this matter. The Division established good cause and compelling need based on specific facts for an order authorizing it to use Arlo’s expunged records at the Title 9 abuse and neglect factfinding trial. It demonstrated that the subject matter of the criminal proceeding will also be the subject matter of the Title 9 trial. The trial court properly granted the Division’s application, and the Court affirms the Appellate Division’s judgment.

1. N.J.S.A. 2C:52-19 provides in part that “[i]nspection of [expunged] files and records, or release of the information contained therein, . . . may be permitted by the Superior Court upon motion for good cause shown and compelling need based on specific facts.” The Legislature thus imposed on the movant the burden to make two distinct showings in order to review or use expunged records pursuant to that exception to the expungement statute: a showing of “good cause” and a showing of “compelling need based on specific facts.” N.J.S.A. 2C:52-19. “Good cause” is a flexible standard. The requirement of “compelling need based on specific facts,” however, denotes an elevated standard, requiring the movant to explain in detail why categories of documents or information that may be among the expunged records are needed in the pending case. When, as here, the movant has been given access to the expunged records, a trial court should expect that showing to be more detailed than a showing made in a typical setting in which the movant is unfamiliar with the records. Second, the Legislature strictly limited the use and dissemination of any expunged records subject to an order entered under N.J.S.A. 2C:52-19. Third, the Legislature further constrained the disclosure and use of expunged records and information by limiting a court’s ability to grant leave to inspect expunged materials to settings in which “the subject matter of the records of arrest or conviction is the object of litigation or judicial proceedings.” Ibid. The movant must thus provide the court with a description of the alleged conduct or incident that led to the arrest and/or conviction of the person whose records were expunged and also explain the nexus between that conduct or incident and the litigation or judicial proceedings in which the movant seeks to use the expunged records. If the movant shows good cause and compelling need based on specific facts and meets the statute’s other requirements, the court may authorize the use of the expunged documents either to support an affirmative claim or to defend against a claim. Ibid. (pp. 14-20)

2 2. Here, the Division established that the criminal and civil proceedings against Arlo concerned the same incident, and that the expunged records were created immediately after Daniel’s injuries. See A.P., 475 N.J. Super. at 486. The Division also demonstrated that the law enforcement and child protection investigations were concurrent and intertwined. The Division thus established a close nexus between its investigation of suspected child abuse and the Monmouth County Prosecutor’s Office’s arrest and prosecution of Arlo. In addition, the Division demonstrated the importance of the expunged documents to this particular Title 9 proceeding, citing the underlying facts. The only witnesses to Daniel’s injuries were Arlo and Tiffany, both of whom stated that the child had a minor accident. Daniel, by virtue of his age and medical condition, was incapable of recounting the incident. Accordingly, expunged records in the prosecutor’s file may provide crucial evidence that cannot be obtained from other sources. Considered together, those factors comprise a showing of “good cause . . . and compelling need based on specific facts.” N.J.S.A. 2C:52-19. N.J.S.A. 2C:52-19 also requires that “the subject matter of the records of arrest or conviction is the object of litigation or judicial proceedings.” That mandate is clearly satisfied here. Finally, N.J.S.A. 2C:52-19 requires that the motion or any order granted pursuant to the motion “shall specify the person or persons to whom the records and information are to be shown and the purpose for which they are to be utilized.” Both the Division’s motion and the order granting the motion specified that the expunged records would be used in the Title 9 factfinding trial, and the order noted that the proceedings were confidential. The trial court properly granted the Division’s motion to use Arlo’s expunged records at the Title 9 factfinding trial. The Court does not rule on the admissibility of any of the expunged records at trial; that determination is for the trial court on remand. (pp. 20-24)

AFFIRMED and REMANDED to the trial court.

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New Jersey Division of Child Protection and Permanency v. A.P., Counsel Stack Legal Research, https://law.counselstack.com/opinion/new-jersey-division-of-child-protection-and-permanency-v-ap-nj-2024.