This case note, published in the William Mitchell Law Review, begins with a short history of the juvenile justice system before examining the statutory framework and prior case law involving juvenile expungements. It will then focus on the details of the J.J.P. case, encapsulating both the Minnesota Court of Appeals and Minnesota Supreme Court decisions.

This note will argue that while the Minnesota Supreme Court may have intended to provide solid footing for expungements in the wake of the decision, the court failed to provide many petitioners actual relief under Minnesota Statutes section 260B.198, subdivision 6.

This note will then analyze the implications of the J.J.P. decision on petitioners and address the gaps left by the majority decision as it relates to relief sought by a petitioner in the areas of employment, housing, and education. Finally, this note will provide suggestions for possible legislative reform to remedy the ineffectiveness of the current statute.