California Legal Brief

The Rule of The People v. Murray Rifat is that a petition to seal arrest records under Penal Code section 851.91 must be denied when there is a causal nexus between the arrest and a subsequent conviction, under circumstances where the defendant pleaded guilty to charges in a separate case filed as part of a plea agreement to dismiss the original charges and the conduct underlying both cases occurred during overlapping time periods.

Appeal from order denying petition to seal arrest records in Superior Court, Riverside County.

Defendant Appellant was Matthew David Murray Rifat — the defendant who was indicted on conspiracy and fraud charges in 2019, later entered into a plea agreement in a separate case, and sought to seal his arrest records.

Plaintiff Respondent was The People — the prosecuting authority who opposed the petition to seal arrest records.

The suit sounded in a petition to seal arrest records under Penal Code section 851.93. No cross-claims were applicable.

The key substantive facts leading to the suit were defendant was indicted in January 2019 on conspiracy, fraud, and money laundering charges related to workers' compensation fraud through Blue Oak Medical Group occurring from 2015-2018. In February 2024, the People filed a new complaint charging defendant with accepting business with reckless disregard for section 550 violations occurring in November 2015. Defendant pleaded guilty to this charge in exchange for dismissal of the original indictment. In February 2025, defendant petitioned to seal his arrest records from the original indictment.

The procedural result leading to the Appeal: The trial court denied defendant's petition to seal arrest records, ruling that there was a causal nexus between defendant's arrest in the original case and his subsequent conviction in the plea agreement case.

The key question(s) on Appeal: Whether the trial court erred in denying defendant's petition to seal arrest records under Penal Code section 851.91 when defendant was convicted of charges in a separate case filed as part of a plea agreement to dismiss the original charges.

The Appellate Court held that the petition was properly denied because there was a causal nexus between defendant's arrest in the original indictment and his conviction in the subsequent case, where both cases involved related conduct during overlapping time periods, the plea agreement expressly linked the cases, and defendant received credit for time served from the original case.

The case is inapplicable when there is no causal relationship between the arrest sought to be sealed and any subsequent conviction, when the subsequent charges arise from completely unrelated conduct, or when the defendant was separately arrested for the subsequent charges rather than the charges being filed as part of a plea agreement.

The case leaves open what degree of factual similarity is required to establish a causal nexus between an arrest and subsequent conviction, and whether section 851.91 relief might be available for portions of arrest records when only some charges result in conviction through plea agreement.