Mays v. Andrew William Schroeder acting

Background

Yolanda Mays, acting in her individual capacity and as trustee for the heirs and next of kin of Tommy Holmes, sued Andrew William Schroeder, Mark Joseph Suchta, Alan Douglas Salvosa (each acting in their individual capacity), and the City of Minneapolis. The City filed two body-worn camera (BWC) videos as exhibits to a declaration in support of the Minneapolis Defendants' Motion for Summary Judgment. Those videos captured the events underlying the lawsuit and were, according to the court, heavily relied upon in the court's order on the parties' motions for summary judgment.

The parties submitted a Joint Motion for Continued Sealing under Local Rule 5.6(d), asking the court to keep the two BWC videos (Docket Entries 76 and 77) sealed from the public. Defendants argued that Minnesota Statute § 13.825—part of the Minnesota Government Data Practices Act (MGDPA)—classifies BWC footage as generally nonpublic, and that the videos showed the faces of uninvolved, non-law-enforcement bystanders. Plaintiff opposed continued sealing, arguing that the state data law does not control federal court sealing decisions, that the recordings do not contain genuinely confidential information, that law enforcement activities are matters of public concern, and that any bystander privacy concerns could be addressed through redaction rather than full sealing.

Legal Standard

Federal courts recognize a common-law right of public access to judicial records. The Eighth Circuit has explained that this right bolsters public confidence in courts, allows citizens to evaluate judicial proceedings, and provides a measure of accountability. The right is not absolute: courts must weigh the public's interest in access against countervailing interests that favor confidentiality. However, the court emphasized, only the most compelling reasons can justify keeping judicial records from the public.

When a document is filed in support of a dispositive motion (a motion that could end the case on the merits, such as a motion for summary judgment), it is "integrally involved" in resolving the case. That means the presumption of public access carries extra weight, and the party seeking to keep the document sealed faces a heightened burden.

Analysis and Ruling

Magistrate Judge Wright first determined that Minnesota's MGDPA—and specifically Minn. Stat. § 13.825—does not govern whether federal courts may seal judicial records. The MGDPA regulates how state and local government entities handle data; by its own terms, the judiciary is not governed by the statute. The court concluded that citing the MGDPA is insufficient to meet the heightened burden required to keep documents sealed when those documents were filed in connection with a dispositive motion.

The court also carefully considered the privacy interests of individuals shown in the videos. Notably, Plaintiff—whose home appears in the footage and who is the trustee for the heirs of Tommy Holmes (who appears in the footage)—affirmatively sought public disclosure of the videos. As to non-law-enforcement bystanders shown in the footage, the court found that their privacy interests did not outweigh the public's interest in reviewing the footage. The court noted, however, that Defendants may, if practicable, file redacted versions that blur or distort only the non-law-enforcement third parties.

The court denied the Joint Motion for Continued Sealing and ordered Docket Entries 76 and 77 unsealed in accordance with the Local Rules.