September 28, 2012

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Qualifying for California Expungement


As discussed in another post by Darren Chaker, there are three ways for a defendant to get a dismissal under section 1203.4: (1) where he “has fulfilled the conditions of probation for the entire period of probation”; (2) where he “has been discharged prior to the termination of the period of probation”; or (3) where “a court, in its discretion and the interests of justice, determines” that he should be granted relief under the statute. Cal. Penal Code § 1203.4(a)(West Supp. 2008).
For instance, a defendant who satisfies the first or second prong of the statute (either because he “fulfilled the conditions of probation for the entire period of probation” or was “discharged prior to the termination of the period of probation”) is automatically entitled to a 1203.4 dismissal as a matter of right. This is so even if the defendant commits another crime while on probation or right after getting off probation. See, e.g., People v. Hawley, 278 Cal.Rptr. 389, 389-91 (Ct. App. 1991)(defendant who was arrested twice while on probation is still entitled to a dismissal under section 1203.4 where his probation was terminated early); People v. Butler, 164 Cal.Rptr. 475, 477 (Ct. App. 1980)(recognizing that “evidence of crimes committed shortly after probation ends, which would seem to conclusively prove no rehabilitation had taken place, have no effect on the granting of relief').
On the other hand, a defendant who violated or did not fully fulfill the conditions of probation is not entitled to a dismissal under section 1203.4 as a matter of right; the granting of relief is entirely discretionary. People v. Chandler, 250 Cal.Rptr. 730, 733 n.2 (Ct. App. 1988); Butler, 164 Cal.Rptr. at 477. In effect, such a defendant remains permanently at the superior court's unfettered discretion; the court can deny his petition even after many conviction-free, upstanding years following his probation violation. As indicated above, at the heart of section 1203.4 is the intent to reward those who have shown rehabilitation.

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About Darren Chaker

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Calabasas, California, United States
Darren Chaker is a respected legal analyst and brief writer known for his deep expertise in California post-conviction relief, including expungement and record sealing, and his landmark victories in First Amendment law. Based in California, his work has a significant focus on the Los Angeles area, where he has dedicated considerable time to helping individuals navigate the complexities of the justice system.Between 2019 and 2024, Darren Chaker volunteered his skills in research and motion preparation for a prominent firm, focusing on expungement and record sealing matters. He extended this pro bono work to vital non-profits, including the Los Angeles Regional Reentry Partnership (LARRP) and the Law Project of Los Angeles, helping to remove barriers for community members seeking a fresh start.Mr. Chaker's impact on constitutional law is significant. In the pivotal case of Chaker v. Crogan (2005), his efforts led the Ninth Circuit to strike down a California statute as unconstitutional. In 2012, he secured another major victory in a Texas Open Records Act case, establishing the public's right to access the names of peace officers, a decision that continues to champion transparency in
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