John Larracuente v. United States

Summary

The District of Columbia Court of Appeals affirmed the denial of John Larracuente’s motion to seal records relating to his marijuana possession-with-intent-to-distribute conviction. The court held that eligibility under the District’s record-sealing statute requires a case-specific analysis of whether the underlying conduct was decriminalized, rather than a categorical analysis based solely on the offense of conviction. Because the record supported a finding that Larracuente possessed more than two ounces of non-home-grown marijuana, and because discretionary sealing did not extend to still-criminal conduct, the court also upheld denial without a hearing.

Holdings

1. The record-sealing statute requires a case-specific-facts approach rather than a categorical approach focused only on the least culpable conduct satisfying the elements of the offense.
2. The government met its burden of proving by a preponderance of the evidence that Larracuente possessed a quantity of marijuana exceeding the amount decriminalized under D.C. Code § 48-904.01(a)(1).
3. D.C. Code § 16-803.02(a)(2) does not authorize the Superior Court to seal records pertaining to conduct that remains criminal or illegal.
4. The Superior Court did not abuse its discretion or deny due process by denying the motion without a hearing.

Questions Presented

1. Whether D.C. Code § 16-803.02 requires a categorical approach or a case-specific-facts approach to determine whether conduct underlying a criminal record was decriminalized or legalized.
2. Whether the government met its burden of proving by a preponderance of the evidence that Larracuente's marijuana possession was not decriminalized.
3. Whether D.C. Code § 16-803.02(a)(2) permits discretionary record-sealing in the interest of justice for conduct that remains criminal or illegal.
4. Whether the Superior Court abused its discretion or denied due process by denying the sealing motion without a hearing.

Disposition

affirmed