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In re Expungement of the Involuntary Civil Commitment Record of M.D.V.

New Jersey Appellate Division

November 9, 2020

In In re Expungement of the Involuntary Civil Commitment Record of M.D.V., the Appellate Division reviewed an order from the Superior Court-Law Division that denied the petitioner’s application to expunge his civil commitment records “with prejudice.” The Appellate Division credited the lower court’s thoughtful analysis of the two-pronged test enunciated in N.J.S.A. 30:4-80.9 but held that any denial of this kind of order should be without prejudice.

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