Doe v. United States

John Doe (plaintiff) was arrested when he was a juvenile for failing to pay a special tax on marijuana that had been exported. Doe pleaded guilty and was placed on probation for three years by federal authorities. Before the probationary period was up, Doe’s conviction was vacated, and his record was sealed. Doe indicated that the judge that sealed his record told him that he would not need to disclose the record to anyone after seven years. This led Doe to believe that his juvenile record would not affect his future employment. The statute that Doe violated was later repealed. For 27 years after the conviction, Doe was never arrested or convicted of a crime. Doe also worked in the auto-sales industry for 20 years. Doe was employed as a sales manager when a routine background check showed that he had been convicted as a juvenile. Federal law prevented a person who had been convicted of an offense involving dishonesty from employment with an institution that was federally insured. In addition, Doe’s employer had a policy of firing any employee with a past criminal conviction. Doe’s supervisor informed Doe that if he did not have his record expunged, he would be fired. Doe filed an action for equitable relief against the United States (defendant) to have his criminal arrest record expunged. The United States moved for dismissal or, alternatively, for summary judgment. The United States failed to show an interest in keeping Doe’s record and argued that there were no extraordinary circumstances in Doe’s case and that expunction should be reserved for extreme cases.