Amen El Pharaoh El-Forever Left-i v. Schnell

Background

The plaintiff sent an August 4, 2020 letter asking the court to seal his application to proceed without paying filing fees. The application, called an IFP application, had been filed under temporary seal while the court considered the request. The order interpreted the request under Local Rule 5.6(e) of the District of Minnesota.

Court’s analysis

The court explained that judicial records generally carry a common-law right of public access. That right supports public confidence and allows the public to evaluate the fairness and reasonableness of court proceedings. The right is not absolute, however, so the court must weigh the public’s interest in access against the interests served by confidentiality.

An IFP application must include an affidavit stating the applicant’s assets and inability to pay court fees. The court noted that such applications are typically public records. It found that the plaintiff had not sufficiently explained why publicly filing the information would cause actual, identifiable harm. Even assuming he was concerned about financial or dependent information becoming public, the court found the information in the application general and vague enough to avoid a risk to him. The court also stated that it could not identify sensitive information—such as account numbers, Social Security numbers, or the names of dependents—that would outweigh the public’s right to access information relevant to the court’s rulings.

Ruling

Judge Elizabeth Cowan Wright denied the plaintiff’s request to seal the IFP application. The court also ordered docket entry 7 unsealed under Local Rule 5.6.