Doe v. Mayorkas

Background

John Doe filed a sealed amended complaint and a public redacted copy. Doe also moved to file the amended complaint under a pseudonym and under seal. The court had previously granted a similar request for the original complaint.

Doe argued that the amended complaint contained confidential and sensitive information about Doe and people who were not parties to the case. Doe also argued that publicly disclosing Doe’s identity could cause significant harm and threaten the lives and safety of Doe and family members.

Court’s Analysis

The court recognized a common-law right of public access to judicial records but explained that the right is not absolute. Courts must balance public access against legitimate confidentiality interests. The court found good cause to seal the amended complaint because Doe’s interest in confidentiality outweighed the public interest in access.

The court also considered whether Doe could proceed under a pseudonym. It found that Doe was challenging governmental activity and that publicly disclosing Doe’s name could be life-threatening to Doe and family members. The court further found that the defendants would not be prejudiced because Doe’s identity appeared in the unredacted complaint filed under seal and was accessible to the defendants. The risk of serious harm outweighed the public interest in disclosure.

Ruling

The court granted Doe’s Motion to File Amended Complaint Under Pseudonym and Seal the Amended Complaint. It directed the clerk to keep the sealed amended complaint on the sealed docket and allowed Doe to proceed under a pseudonym. If they object, the defendants may file a motion to reconsider within 14 days of the order.