Missouri Court of Appeals, Western District / Jul 9, 2024
D.B. vs. Missouri State Highway Patrol Criminal Justice Information Services, Buchanan County Prosecuting Attorney(s), Circuit Attorney(s)
D.B. appealed the trial court's partial denial of his petition to expunge two felony convictions for manufacturing methamphetamine. The trial court expunged one conviction but found the two offenses were not part of the "same course of criminal conduct" under section 610.140.1, RSMo, thus limiting D.B. to one expungement. The appellate court affirmed, holding that the Missouri State Highway Patrol had standing to object, the trial court properly considered the lifetime expungement limit, and D.B.'s offenses were not part of the same course of criminal conduct due to a significant temporal separation and intervening non-criminal conduct.