Lacy v. Miyamoto
- Haywood Gilliam
- 3:21-cv-03377
- U.S. District Court · Northern District of California
- 3
In Lacy v. Miyamoto, Judge Gilliam granted the request to seal a probation report in Lacy’s federal habeas case.
The order allows Respondent Paul Miyamoto to keep the probation report at Dkt. No. 13-3 under seal, limiting public access to that document during the case and any appellate proceedings.
What happened
Lacy v. Miyamoto concerns a request by Respondent Paul Miyamoto to file under seal a probation report from Lacy’s underlying criminal matter in Lacy’s petition challenging his state custody. The report was docketed as Dkt. No. 13-3.
The court said the report was only indirectly related to the merits of the petition. It also noted that California court rules require detailed personal information in probation reports to remain confidential. Because the report met the lower standard for sealing documents only indirectly related to a case, the court approved the request.
The court granted the motion to seal and ordered Dkt. No. 13-3 to remain sealed until this case and any appeals end. If Respondent’s counsel does not request the documents’ return afterward, they will be destroyed under the federal courts’ normal records policy. Judge Haywood S. Gilliam, Jr. issued the order.
The detailed version
- Lacy v. Miyamoto · No. 3:21-cv-03377
- Haywood Gilliam
- June 17, 2022
Background
Roy Donovan Lacy, identified as a state prisoner, filed a petition for a writ of habeas corpus under 28 U.S.C. § 2254. Respondent Paul Miyamoto filed an administrative motion to seal a probation report from Lacy’s underlying criminal matter. The report appears at pages 1077–1100 of the clerk’s transcript and was docketed as Dkt. No. 13-3.
Legal standard
Court filings are generally presumed to be available to the public. For records closely related to the merits of a case, courts generally require “compelling reasons” supported by specific factual findings to overcome that presumption. But records only “tangentially related” to the merits are subject to the lower “good cause” standard under Federal Rule of Civil Procedure 26(c). That standard requires a particularized showing that disclosure would cause specific prejudice or harm.
Court’s analysis
The court determined that the probation report was only tangentially related to the merits of Lacy’s habeas petition. The court also noted that California Rules of Court 8.45–8.47 require detailed personal information in probation reports to be kept confidential. Based on those considerations, the court found that sealing the report was justified.
Disposition
The court GRANTED Respondent’s request to file the probation report under seal. Dkt. No. 13-3 must remain under seal until the conclusion of the case and any appellate proceedings. If Respondent’s counsel does not request that the documents be returned after those proceedings, the documents will be destroyed under the normal records-destruction policy of the United States Courts. The order terminated Dkt. No. 13.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.