Iowa Supreme Court Adopts Whole-File Expungement for Eligible Misdemeanor Convictions Under Iowa Code § 901C.3

Introduction

In J. Doe v. Iowa District Court for Polk County, the Supreme Court of Iowa resolved an important question about the scope of expungement relief available under Iowa Code § 901C.3. The statute entitles qualifying defendants convicted of a misdemeanor offense to have the “record of such a criminal case” expunged. The dispute here centered on what must be expunged when a single criminal case file contains both an expungable misdemeanor conviction and a dismissed charge. Specifically: does § 901C.3 require expungement of only those filings associated with the misdemeanor conviction (a “mixed-file” approach), or must the court expunge the entire criminal case file associated with that case number (a “whole-file” approach)?

The plaintiff, J. Doe, was charged in 2013 with domestic abuse assault and child endangerment. As part of a plea agreement, the State amended the domestic abuse charge to disorderly conduct (a simple misdemeanor) and dismissed the child-endangerment count. In 2023, more than eight years later, Doe petitioned for expungement under § 901C.3. The district court granted expungement “as to count I only” and the clerk redacted certain filings but left other parts of the file—including docket information indicating the presence of a dismissed count—publicly accessible. Doe moved to implement a full expungement under Iowa Rule of Criminal Procedure 2.84(4), arguing that § 901C.3 required expungement of the entire case file. The district court denied the motion. Doe sought certiorari, which the Iowa Supreme Court granted.

The key issue: how to understand “the record of such a criminal case” for purposes of expungement under § 901C.3 when a case includes both an eligible misdemeanor conviction and other non-conviction dispositions, such as dismissals.

Summary of the Opinion

The Court holds that § 901C.3 mandates whole-file expungement: when the statutory prerequisites are met and the misdemeanor conviction is eligible, the court must expunge the record of the entire criminal case associated with that single case number, not merely the conviction-related filings.
The Court rejects “mixed-file” expungement as incompatible with the statutory text and structure, the definitional cross-references in the Code, administrative workability, and the statute’s purpose of avoiding stigma from public access to criminal records.
Where a nonexpungable conviction (e.g., a felony or a misdemeanor excluded by § 901C.3(2)) exists within the same case file, the presence of that conviction renders the entire case ineligible for expungement under § 901C.3.
The Court sustains the writ, vacates the district court’s order, and remands for full implementation consistent with a whole-file expungement approach.

Analysis

Precedents Cited and Their Influence

The Court’s decision draws heavily on established interpretive principles and prior expungement decisions, particularly:

Doe v. State (Doe 2017), 903 N.W.2d 347 (Iowa 2017): In interpreting § 901C.2 (expungement where all charges in a criminal case are dismissed or result in acquittal), the Court held that “criminal case” refers to a separately numbered legal proceeding, i.e., a case-number-by-case-number framework, not a charge-by-charge approach. The Court found “criminal case” ambiguous but, using standard interpretive tools, adopted the case-number definition. That approach made expungement predictable and administrable, avoiding line-by-line review and redaction. Doe 2017 provides the conceptual foundation for applying the same meaning of “criminal case” to § 901C.3.
Doe v. State (Doe 2020), 943 N.W.2d 608 (Iowa 2020): The Court emphasized that Chapter 901C was enacted to mitigate the stigma arising from public access to criminal records—especially where charges are dismissed and for certain minor convictions—because public dockets can lead to “inappropriate inferences.” This purpose favors whole-file expungement; a mixed-file approach leaves visible “breadcrumbs” that reveal the existence of expunged matters.
Christensen v. Iowa District Court, 21 N.W.3d 529 (Iowa 2025): Cited for the certiorari standard—courts act illegally when they misinterpret or misapply a statute. This frames the Court’s authority to correct the district court’s implementation of § 901C.3.
Ackelson v. Manley Toy Direct, L.L.C., 832 N.W.2d 678 (Iowa 2013) and Kragnes v. City of Des Moines, 714 N.W.2d 632 (Iowa 2006): These decisions ground the doctrine of legislative acquiescence: when the legislature adopts similar language after a judicial interpretation, courts presume the legislature accepted the prior construction, absent contrary evidence. Because § 901C.3 was enacted after Doe 2017 and uses materially similar language, the Court infers legislative approval of the case-number concept.
Taft v. Iowa District Court, 828 N.W.2d 309 (Iowa 2013); State v. Iowa District Court, 889 N.W.2d 467 (Iowa 2017); Walthart v. Board of Directors, 667 N.W.2d 873 (Iowa 2003): The Court reiterates canons favoring reasonable, workable, and sensible statutory constructions. Whole-file expungement is more practical and predictable than painstaking mixed-file redaction.

Legal Reasoning

The Court’s reasoning proceeds in several linked steps:

Text and Context: Section 901C.3(1) directs courts to enter an order “expunging the record of such a criminal case” when the defendant with a misdemeanor conviction satisfies the listed prerequisites. The phrase “criminal case” is ambiguous, as recognized in Doe 2017. Reading § 901C.3 alongside § 901C.2 and in light of Doe 2017’s construction, the Court applies the same case-number-by-case-number understanding.
Legislative Acquiescence and Expressio Unius: The legislature enacted § 901C.3 after Doe 2017 and used nearly identical language (“the record of such a criminal case”) despite having elsewhere demonstrated how to authorize a count-by-count approach. For example, § 907.9(4)(b) expressly targets expungement of specific “counts” and “charges.” The contrast suggests that in Chapter 901C, the legislature meant expungement at the case level, not the count level.
Definitions of “Expunge” and Public Access: Section 901C.1 incorporates § 907.1(3)’s definition: an expunged file is “segregated in a secure area or database which is exempted from public access.” Section 901C.3(4) likewise states an expunged record is a “confidential record” exempt from public disclosure under § 22.7. A partially redacted, still-public case file is neither “segregated” nor fully “exempt from public access.” Thus, mixed-file redaction cannot satisfy the Code’s definition of “expunge.”
Administrative Workability: Whole-file expungement is predictable and ministerial; mixed-file expungement requires line-by-line review and redaction to scrub direct and indirect references to the expunged conviction, creating uncertainty, delay, and risk of inadvertent disclosure. The Court favors the sensible and workable approach.
Avoiding “Absurd Results” and Harmonizing with Disqualifications: The State argued that whole-file expungement would enable concealment of nonexpungable convictions (e.g., felonies) merely because they share a case number with an expungable misdemeanor. The Court rejects this, clarifying the rule: if a nonexpungable conviction exists in the same case, the entire case is ineligible for expungement under § 901C.3. Conversely, when a case includes an expungable misdemeanor and a dismissed count, whole-file expungement is permissible (and appropriate), because dismissed charges are independently expungable under § 901C.2.
Statutory Purpose: Minimizing Stigma and Inferences: The whole-file approach best serves Chapter 901C’s purpose. Mixed-file expungements allow the public to infer an expunged conviction from the presence of a visible “Count 2: dismissed,” or similar docket breadcrumbs, thereby perpetuating the stigma the statute seeks to avoid. Whole-file expungement eliminates these inferences without depriving the public of information about genuinely nonexpungable convictions (which, if present, prevent expungement altogether).

Impact and Practical Implications

The decision’s consequences will be significant for courts, clerks, lawyers, and the public:

For Clerks of Court: Implementation should proceed case-number-by-case-number. When a § 901C.3 order is entered, the entire record associated with that case number must be segregated from public access, not partially redacted. This simplifies workflow and reduces the risk of inadvertent disclosure through docket entries, metadata, or stray references.
For Trial Courts: Orders granting expungement should direct the clerk to segregate the entire case file from public access. Courts should avoid count-limited directives (“as to count I only”) in § 901C.3 contexts, because they do not satisfy the statutory requirement to expunge “the record of such a criminal case.”
For Defense Counsel: The ruling strengthens the relief available when clients satisfy § 901C.3’s prerequisites. Counsel should evaluate case composition early: if an otherwise expungable misdemeanor shares a case number with an ineligible conviction, the entire case cannot be expunged. Plea negotiations and case-management strategies may warrant considering whether to consolidate or separate charges into different case numbers, consistent with ethical and procedural rules.
For Prosecutors: The decision clarifies that charging and case-numbering decisions can affect future expungement eligibility. Where the public interest favors long-term visibility, combining expungable and nonexpungable counts in a single case number will prevent later expungement. Conversely, if the State is indifferent to long-term visibility of minor counts, maintaining separate case numbers (where appropriate) may preserve expungement opportunities for minor offenses.
For the Public and Background Screeners: Whole-file expungement will reduce partial visibility that can lead to misinterpretation. Nonexpungable convictions remain publicly accessible; eligible minor misdemeanors and dismissed charges will be fully segregated when expunged, consistent with Chapter 901C’s purposes.
For Existing “Mixed-File” Cases: Defendants whose expungements were previously implemented with partial redaction may seek corrective relief under Iowa R. Crim. P. 2.84(4), citing this decision, to effectuate full-file expungement where § 901C.3 applies.

Complex Concepts Simplified

“Criminal case”: In this context, a criminal case means the entire proceeding associated with a single case number, not an individual count or charge within that case.
Whole-file vs. Mixed-file Expungement: Whole-file expungement removes the entire case file from public access; mixed-file expungement redacts or conceals only parts of the file. The Court rejects mixed-file expungement under § 901C.3.
What “expunge” means in Iowa: A file is segregated into a secure database or area that is exempt from public access. Partial concealment that leaves material accessible does not meet this standard.
Eligibility prerequisites under § 901C.3(1): The defendant must show all of the following: (a) more than eight years have passed since conviction; (b) no pending criminal charges; (c) not previously granted two deferred judgments; and (d) all financial obligations (court costs, fees, fines, restitution, etc.) have been paid. Certain misdemeanors are excluded from expungement eligibility under § 901C.3(2).
Effect of nonexpungable convictions in the same case: If a nonexpungable conviction is present in the same case file, the entire case is ineligible for expungement under § 901C.3.
Certiorari in this context: A mechanism for the Supreme Court to review whether the district court exceeded its jurisdiction or acted illegally (e.g., by misinterpreting a statute). Here, certiorari was sustained because the district court misapplied § 901C.3.

Conclusion

J. Doe v. Iowa District Court for Polk County establishes a clear, administrable rule: expungement under Iowa Code § 901C.3 proceeds on a whole-file basis, keyed to the case number. The Court harmonizes § 901C.3 with related statutes, adheres to the interpretive framework of Doe 2017, and advances Chapter 901C’s fundamental aim of mitigating stigma from criminal records. By rejecting mixed-file expungement, the Court ensures that eligible misdemeanor expungements produce a genuinely confidential, non-public record, free from residual clues that would allow improper inferences.

At the same time, the Court confirms that expungement relief is appropriately limited: when an ineligible conviction is present in the same case, the entire case remains public. This balanced, workable approach will guide trial courts and clerks in implementing expungements, provide clarity for charging and plea practices, and improve the fairness and integrity of criminal-record management in Iowa.

The writ is sustained; the district court’s order is vacated; and the case is remanded for full implementation consistent with the whole-file expungement rule announced by the Court.