Stevenson v. Earls
- Subramanian
- 1:23-cv-10375
- U.S. District Court · Southern District of New York
- 2
In Stevenson v. Earls, Judge Subramanian denied without prejudice the pro se plaintiff’s request to seal her complaint.
Brianna Ashleigh Stevenson, the defendants, and members of the public seeking access to the complaint.
What happened
In Stevenson v. Earls, Brianna Ashleigh Stevenson asked the court to seal her complaint, which included serious allegations of sexual assault and references to a defendant’s wife and children.
Stevenson argued that publishing the complaint could lead to severe reprisals and threaten her physical safety, particularly because she named Atlantic Recording Corporation. She also said an attorney would appear for her after the sealing motion was resolved.
Judge Arun Subramanian denied the motion without prejudice because the public-access presumption had not been overcome. The court temporarily limited access to the complaint until February 16, 2024, allowing a renewed motion; without one showing good cause for sealing, the complaint would be unsealed on February 17, 2024.
The detailed version
- Stevenson v. Earls · No. 1:23-cv-10375
- Subramanian
- Jan. 19, 2024
Background
Brianna Ashleigh Stevenson, proceeding without a lawyer, asked the U.S. District Court for the Southern District of New York to seal her complaint. The complaint was filed on November 24, 2023, and the sealing motion was dated December 1, 2023. Stevenson said the complaint and jury-trial demand contained serious allegations of sexual assault and multiple references to Avery Earls’s wife and children.
Stevenson argued that the seriousness of the allegations and their potential effects on the parties created a reasonable likelihood of reprisals severe enough to threaten her physical safety. She emphasized that Atlantic Recording Corporation, one of the defendants, was an “extremely powerful” record corporation. She also told the court that an attorney would enter an appearance on her behalf after the sealing motion was resolved.
Ruling
The court denied the motion to seal the complaint without prejudice. It explained that court records are generally presumed to be publicly accessible and concluded that the current motion did not overcome that presumption. The court stated that conclusory claims of harm are insufficient to justify sealing.
Although it denied the motion, the court temporarily limited access to the complaint to court users and case participants. That limitation was to remain until February 16, 2024, so Stevenson or her attorney could file a renewed sealing motion with additional detail. If no renewed motion showing good cause for sealing was filed, the court directed that the complaint be unsealed on February 17, 2024. The Clerk of Court was directed to terminate Dkt. 2.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.