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Can Some Juvenile Adjudications be Expunged After a Defendant Successfully Completes Recovery Court? The Supreme Court Will Decide


The Supreme Court announced that it has granted certification in In the Matter of the Expungement of the Criminal/Juvenile Records of P.L. The question presented, as phrased by the Supreme Court Clerk’s office, is “Does the Recovery Court expungement statute, N.J.S.A. 2C:35-14(m), allow for the expungement of juvenile adjudications for offenses that would not otherwise be eligible for expungement under N.J.S.A. 2C:52-2 and N.J.S.A. 2C:52-4.1?” In an opinion reported at 482 N.J. Super. 319 (App. Div. 2025), the Appellate Division, applying de novo review, affirmed the ruling of the Law Division that allowed the expungement in these circumstances.