Murphy v. Warden of Attica Correctional Facility

Background

Donelle Murphy is challenging a New York state conviction through a federal petition. The opinion says that his petition raises, among other issues, claims of ineffective assistance of counsel and violations of his confrontation and due-process rights. The court had directed the respondent to answer the petition and submit relevant state-court documents.

The respondent filed a letter-motion asking permission to file under seal the state-court transcript, the respondent’s appendix, and other documents containing the name of the sexual-assault victim. The respondent said those documents identified the victim. New York Civil Rights Law § 50-b requires sexual-assault victims’ identities to remain confidential and prohibits public employees from making documents disclosing those identities available for public inspection.

Legal Standard

The court explained that judicial documents—materials relevant to the court’s work and useful in the judicial process—generally carry a common-law presumption of public access. Courts must weigh the strength of that presumption against competing considerations, including the privacy interests of people resisting disclosure. A court may seal records when doing so is essential to protect an important interest and the sealing is narrowly tailored to that purpose.

Ruling

The court held that the state-court transcript and habeas appendix qualified as judicial documents, so the public-access presumption applied. But it found that protecting the sexual-assault victim’s identity was a compelling reason to restrict access. Because redacting the victim’s name did not appear practical, the court concluded that sealing the documents identified by the respondent was narrowly tailored to protect that identity.

Judge James L. Cott granted the request to file the state-court transcript and habeas appendix under seal. He also directed the clerk to close Docket Number 23 and mark it as granted. The order addressed the sealing request; it did not decide the merits of Murphy’s petition.