Jane Doe v. Derek D. Hammond

Summary

The United States District Court for the Eastern District of Michigan grants in part and denies in part Plaintiff Jane Doe’s motion to seal her brief and exhibits supporting a motion for default judgment in an assault-and-battery and intentional-infliction-of-emotional-distress action. The court permits sealing of the hospital record and psychiatric evaluation, but requires narrower redactions to the remaining materials, including names, personal identifying information, and financial account information.

Holdings

1. A party seeking to seal judicial records must overcome the strong presumption of public access by showing compelling reasons, and the requested sealing must be narrowly tailored on a document-by-document and line-by-line basis.
2. The motion to seal was properly denied as to receipts, the home-closing statement, bank statements, the affidavit, and the police incident report because the asserted privacy interests could be protected through targeted redactions.
3. The court granted the motion to seal the hospital emergency report and psychiatric evaluation because Plaintiff's interest in protecting those medical records outweighed the public's interest in access.

Questions Presented

1. Whether Plaintiff established compelling reasons to seal her entire damages brief and all attached exhibits.
2. Whether the requested sealing was narrowly tailored to protect medical, mental-health, personal-identifying, and financial information.
3. Whether the hospital emergency report and psychiatric evaluation should remain under seal despite the public-access presumption.

Disposition

other