The following excerpt is from Shipp v. Todd, 568 F.2d 133 (9th Cir. 1978):
1 The power to order expungement of a state arrest record is a narrow one and should be reserved for unusual or extreme cases, for example, "where the arrest itself was an unlawful one, or where the arrest represented harassing action by the police, or where the statute under which the arrestee was prosecuted was itself unconstitutional." United States v. Linn, 513 F.2d 925, 927 (10th Cir. 1975).
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