Scheffler v. New Hope, City of

Background

Troy K. Scheffler, who represented himself, filed an amended complaint that included the personal home addresses of several District Court judges for the State of Minnesota. Magistrate Judge Brisbois ordered the Clerk’s Office to keep the amended complaint under seal and directed Scheffler to file a redacted version omitting those addresses.

Scheffler objected to the magistrate judge’s orders. He argued that the court had no authority to seal his amended complaint, that disclosure of the addresses was not a needless safety threat, and that the addresses were unverified. The magistrate judge reaffirmed the earlier order.

Court’s analysis

The district court reviewed the objections under Federal Rule of Civil Procedure 72(a), which permits a district judge to change a magistrate judge’s order on a nondispositive pretrial matter if it is clearly erroneous or contrary to law.

The court explained that Federal Rule of Civil Procedure 5.2 requires limited redaction of personal information from public filings and allows a court to order additional redaction for good cause. The court stated that judges’ home addresses are protected and that courts have broad discretion to address security concerns, particularly where the security measure does not prejudice the plaintiff.

The court found that the judges’ personal home addresses were not relevant to Scheffler’s claims and that there was no public interest in making those addresses available. It concluded that protecting the judges’ privacy and safety, including against unsolicited contact by strangers to the case, outweighed the public right of access to those addresses.

Ruling

Judge Susan Richard Nelson overruled Scheffler’s objections, adopted Magistrate Judge Brisbois’s orders in their entirety, and directed Scheffler to file a redacted version of his amended complaint. The court did not decide the underlying claims in the amended complaint.