Casey Williams v. The Village of Junction City, et al.

Williams · United States District Court for the Southern District of Ohio, Eastern Division · January 2, 2026 · No. 2:25-cv-1507

Summary

The United States District Court for the Southern District of Ohio denies Plaintiff Casey Williams’s motion to seal the complaint and future pleadings referring to sealed Ohio criminal records. The court holds that Ohio’s state-court sealing statute does not overcome the strong federal presumption of public access to judicial records and that the motion fails to provide the document-specific, compelling reasons required by Sixth Circuit precedent.

Holdings

  1. A party seeking to seal federal judicial records must establish compelling reasons for secrecy through a detailed, document-by-document analysis supported by reasons and legal citations; Plaintiff's generalized reliance on the state sealing order did not satisfy that standard.
  2. Ohio Revised Code § 2953.32 does not, by itself, provide sufficient grounds to overcome the presumption of public access to federal court records or require the federal court to seal pleadings containing references to records sealed by an Ohio court.

Questions Presented

  1. Whether the Complaint and all subsequent pleadings referring to Plaintiff's Ohio-sealed criminal records should be filed under seal in federal court.
  2. Whether Ohio Revised Code § 2953.32, standing alone, provides sufficient grounds to overcome the presumption of public access to federal judicial records.

Disposition

other

Cases Cited (9)

  • Stanley v. Turner Oil & Gas Properties, Inc., No. 2:16-CV-386, 2017 WL 5068444, at *1 (S.D. Ohio July 24, 2017)(followed)
  • Shane Grp., Inc. v. Blue Cross Blue Shield of Michigan, 825 F.3d 299, 305 (6th Cir. 2016)(followed)
  • In re Knoxville News–Sentinel Co., 723 F.2d 470, 476 (6th Cir. 1983)(followed)
  • White v. Wilberforce Univ., No. 1:16-CV-1165, 2017 WL 3537233, at *2 (S.D. Ohio Aug. 17, 2017)(followed)
  • Rudd Equip. Co., Inc. v. John Deere Constr. & Forestry Co., 834 F.3d 589, 594–95 (6th Cir. 2016)(followed)
  • Baxter Int’l, Inc. v. Abbott Labs., 297 F.3d 544, 548 (7th Cir. 2002)(followed)
  • Morrison v. Bd. of Trs. of Green Twp., 529 F. Supp. 2d 807, 819 (S.D. Ohio 2007), aff’d, 583 F.3d 394 (6th Cir. 2009)(followed)
  • Karl v. Bizar, No. 2:09-cv-34, 2009 WL 3644115, at *3–4 (S.D. Ohio Oct. 28, 2009)(followed)
  • Raj Plastic Surgery, LLC v. Raj, No. 1:20-CV-00751, 2020 WL 4582690, at *2–3 (N.D. Ohio Aug. 10, 2020)(followed)

Cited In (0)

No citing cases on record yet.

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