Summary
The United States District Court for the Western District of Missouri denied Plaintiff Fredric Darnell Travis’s pro se motion to seal the case. Applying the common-law presumption of public access to judicial records, the Court found that Plaintiff had not provided a compelling reason for sealing the case, while noting that certain information may still be redacted under Federal Rule of Civil Procedure 5.2.
Topics
Practice areas
Questions Presented
- Whether the plaintiff established a compelling reason sufficient to overcome the common-law presumption of public access to judicial records and justify sealing the entire case.
Holdings
- A party seeking to seal judicial records must provide compelling reasons that outweigh the common-law right of public access; a conclusory assertion of confidential or proprietary information, without supporting context, is insufficient.
Key quotations
“Generally speaking, there is a common-law right of access to judicial records, but that right is not absolute.” (511)
“The presumption of public access to judicial records may be overcome if the party seeking to keep the records under seal provides compelling reasons for doing so.” (511)
Factual background
Travis sought to seal the entire case and requested a private evidentiary conference, asserting that confidential, proprietary, private, and restricted information would cause irreparable harm if publicly disclosed. He did not provide additional context or identify specific information justifying sealing, and the court noted that his only claim concerned the Fair Credit Reporting Act.
Procedural history
Fredric Darnell Travis filed a pro se motion to seal the case. Defendant did not file suggestions in opposition, and the court denied the motion on the merits because Travis failed to identify a compelling reason to overcome the presumption of public access to judicial records.