CHARLES RAY REID, IV v. STATE OF MARYLAND
Court of Special Appeals, Battaglia, September 27, 2018,
Expungement – A person who wants his criminal record removed from Maryland Case Search should file an expungement, not sue the courts

Facts from the Case
In 2014, Charles Reid was charged with second-degree assault in St. Mary’s County. The State’s Attorney’s Office dismissed the case a few months later.
In 2016, Reid filed a lawsuit against the State seeking a declaratory judgment that his records should be removed from Maryland Judiciary Case Search.
The State moved to dismiss Reid’s lawsuit on the grounds that he could just file an expungement to get the result that he wanted and therefore a declaratory judgment lawsuit was inappropriate.

Law from the Case
Held: The Court of Special Appeals held that declaratory judgment is inappropriate when there’s already a procedure in place to get what you want.
From the Case: “In light of the comprehensive nature of the expungement statute and because declaratory judgment is disfavored when a complete statutory remedial scheme exists, we hold that Reid must initially avail himself to the strictures of the expungement statute” before he can file a lawsuit.