Simpson v. State Highway Patrol Criminal Records Repository

The Missouri State Highway Patrol (“MSHP”) appeals the trial court’s judgment expunging Dominique Roshaud Simpson’s (“Petitioner”) arrest records relating to an alleged ordinance violation.1 See section 610.122. In two interrelated points, MSHP challenges the trial court’s findings that (1) “[t]he arrest was based on false information” and (2) “[tjhere is no probable cause, at the time of the action to expunge, to believe the individual committed the offense.” Finding merit in MSHP’s points, we reverse the judgment of the trial court.2

Applicable Principles of Review and Governing Law

We will…