Smith v. Duke
- Haywood Gilliam
- 4:20-cv-04335
- U.S. District Court · Northern District of California
- 3
In C. Jay Smith v. T. Duke, Judge Gilliam granted Smith’s motion to seal portions of correctional records attached to defendants’ summary-judgment materials.
C. Jay Smith, whose correctional records were ordered sealed in part, and the public, which will receive access to a redacted version of the filings.
What happened
In C. Jay Smith v. T. Duke, C. Jay Smith asked the court to seal portions of a correctional-record exhibit filed with the defendants’ motion for summary judgment. The records were already publicly available on the docket.
Smith argued that the records falsely indicated that Smith had committed a sex crime and could increase the risk of physical violence while Smith remained incarcerated. Smith also identified being a transgender woman in the custody of the California Department of Corrections and Rehabilitation as a vulnerability. The court found that the public interest in the information was limited because Smith’s criminal history was not at issue, the court had not relied on the information in deciding the summary-judgment motion, and the parties had settled the case.
Judge Haywood S. Gilliam, Jr. granted the motion to seal portions of the exhibit. He directed the clerk to lock the docket entry containing the material and directed Smith to coordinate with the defendants to file a public, redacted version within seven days.
The detailed version
- Smith v. Duke · No. 4:20-cv-04335
- Haywood Gilliam
- Nov. 5, 2025
Background
C. Jay Smith filed an administrative motion to seal materials submitted in support of the defendants’ motion for summary judgment. The motion sought to seal portions of Exhibit F to the Declaration of Eric Miersma. The opinion describes the exhibit as containing confidential correctional records and states that it remained available on the public docket.
Legal standard
Because the material was attached to a dispositive motion—a motion that could resolve the case—the court applied the “compelling reasons” standard. Under that standard, the party seeking to seal judicial records must identify compelling reasons that outweigh the public’s strong interest in access to court records. The court also considered the requirement that parties explore reasonable alternatives, limit sealing, and avoid sealing entire documents when redaction would suffice.
Court’s analysis
Smith argued that portions of the records falsely indicated that Smith had committed a sex crime. Smith contended that other incarcerated people’s discovery of those statements could increase the risk of physical violence while Smith remained incarcerated. Smith also identified being a transgender woman as a factor contributing to vulnerability in the custody of the California Department of Corrections and Rehabilitation.
The court found that the public’s interest in the information was minimal. It stated that Smith’s criminal history was not at issue, that the court had not relied on the information in deciding the motion for summary judgment, and that the parties had settled the case. The court concluded that Smith had shown compelling reasons to seal the information.
Ruling and required filing
Judge Haywood S. Gilliam, Jr. GRANTED the motion to seal portions of Exhibit F to the Declaration of Eric Miersma filed in support of the defendants’ motion for summary judgment. The clerk was directed to lock Docket No. 109 so that it would no longer be publicly available. Smith was directed to coordinate with the defendants to file a public version of the defendants’ motion for summary judgment and accompanying exhibits, including the declaration with proposed redactions to Exhibit F. Smith was directed to file that redacted version within seven days of the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.