Brenda Mitze v. Andrew M. Saul

Summary

The Seventh Circuit affirmed denial of a motion to seal court opinions and records in a social security disability case, holding that a strong presumption of public access to judicial decisions outweighs a claimant's privacy concerns, even when publication of medical details leads to harassment or theft. The court noted that redaction, not sealing, is the preferred remedy for sensitive information, and that HIPAA does not restrict courts or news outlets from publishing information from public records. The court also observed that while existing protections like anonymity or redaction may be inadequate for social security claimants, it was too late for the plaintiff to seek sealing after the case had concluded and opinions were already public.

Holdings

1. The district court did not abuse its discretion because a strong presumption exists in favor of publishing dispositional orders, and Mitze offered no reason to overturn that tradition.
2. News outlets have the right to publish information obtained from public court records, so the district court cannot order removal.
3. HIPAA regulates only healthcare providers and their affiliates, not courts or press.

Questions Presented

1. Whether the district court abused its discretion in denying the motion to seal its order affirming the ALJ's decision.
2. Whether the district court had authority to order news outlets to remove articles about the decisions.
3. Whether publication of details of her case violates HIPAA.

Disposition

affirmed