Background
Rachele A. Teague sought to expunge and seal records relating to three charges dismissed in Knox County case No. 06-CF-219. In that case, Teague pleaded guilty in 2006 to unlawful delivery of a controlled substance and received a three-year prison sentence. The State dismissed the remaining counts—another delivery charge, a possession charge, and obstruction of justice—by nolle prosequi as part of the plea agreement.
At a January 2026 hearing, the circuit court granted Teague’s request to seal the records but denied expungement. The court reasoned that the dismissed counts arose from the same facts and circumstances as the count of conviction and that expunging the related police information was not in the public interest. Teague appealed pro se.
The Court’s Holding
The Illinois Appellate Court, Fourth District, affirmed. It held that the circuit court did not abuse its discretion by denying expungement of the three charges dismissed under the plea agreement in the same case in which Teague was convicted of unlawful delivery of a controlled substance.
The appellate court applied abuse-of-discretion review to the expungement ruling. It rejected Teague’s contention that the circuit court had relied on improper considerations when it considered the dismissed charges’ relationship to her conviction, agreeing with the State that denial was within the court’s discretion.
Key Takeaways
- A denial of expungement is reviewed for abuse of discretion.
- A court may deny expungement of charges dismissed under a plea agreement when they are in the same case as a resulting conviction.
- Sealing may be granted even when expungement is denied.
Why It Matters
The order underscores that dismissal of individual counts does not require expungement when those counts were dismissed as part of a plea resolving the same criminal case. Trial courts retain discretion to preserve related records while allowing sealing where appropriate.