Cumpton v. Wonnell et al

1
IN THE UNITED STATES DISTRICT COURT
FOR THE DISTRICT OF KANSAS
SHARA CUMPTON,
Plaintiff,
v.
ROBERT WONNELL, et al.,
Defendants.
Case No. 25-CV-2619-DDC-TJJ
ORDER
This matter is before the Court on pro se Plaintiff’s Request to Seal Records in Equity
(ECF No. 5). Plaintiff’s motion requests the record be sealed to protect sensitive trust records,
private identifying information, and financial data. Plaintiff argues disclosure of these records
would cause unnecessary and irreparable harm.
There is a longstanding common-law right of public access to judicial records.1 This right
“is fundamental to the democratic state” and preserves “the integrity of the law enforcement and
judicial processes” by allowing the public to see how courts make their decisions.2 The right of
access is not absolute, but the party seeking to seal a judicial record must show “some significant
interest that outweighs” the public interest in access to the records.3 This burden is “heavy,” and
sealing is appropriate only when the interest in confidentiality is “real and substantial.”4 A party
1 McWilliams v. Dinapoli, 40 F.4th 1118, 1130 (10th Cir. 2022).
2 Id. (citing United States v. Bacon, 950 F.3d 1286, 1297 (10th Cir. 2020)).
3 Id. (quoting Mann v. Boatright, 477 F.3d 1140, 1149 (10th Cir. 2007)).
4 Id. at 1130–31.
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overcomes the presumption in favor of access to judicial records by articulating a real and
substantial interest that justifies depriving the public of access to the records that informs the
court’s decision-making process.5
The Tenth Circuit and this District has regularly “allowed sealing of documents reflecting
a party’s finances.”6 Disclosure of Plaintiff’s unredacted financial and personally identifying
records is sufficient to establish a real and substantial private harm that would overcome the
public’s right of access to judicial records.7 Plaintiff, however, has not alleged a real and substantial
interest that would overcome the presumption in favor of public access to judicial records and
justify placing all the documents filed in this case under seal. Instead, Plaintiff must comply with
the procedures for filing a motion to seal or redact documents, set forth in D. Kan. Rule 5.4.2, for
each specific document she seeks to file under seal or be redacted.
The Court has reviewed the six docket filings to date and notes that Plaintiff’s Motion to
Proceed Without Prepayment of Fees (ECF No. 4) and her Affidavit of Financial Status (ECF No.
4-1) are already filed under seal. Further, Plaintiff’s Supplemental Petition in Equity for Leave to
Deposit into Court Registry (ECF No. 6) is provisionally sealed, and Plaintiff may still timely
request the motion be permanently sealed.8 Plaintiff attaches a copy of her birth certificate to the
Complaint (ECF No. 1-2), though containing personally identifying information, the document
5 Brown v. Flowers, 974 F.3d 1178, 1187–88 (10th Cir. 2020).
6 Parker v. United Airlines, Inc., 49 F.4th 1331, 1343 (10th Cir. 2022).
7 See Administrative Procedure for Filing, Signing, and Verifying Pleadings and Papers by
Electronic Means in the U.S. District Court for the District of Kansas (Civil Cases), at 18–19 (“[P]arties
may modify or partially redact other confidential information as permitted by the court (e.g., driver’s license
numbers, medical records, employment history, individual financial information, and proprietary or trade
secret information.)”).
8 See D. Kan. R. 5.4.2 (c) (Motions to seal “must be filed within 7 days after the document is filed
provisionally under seal”).
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appears to have already been redacted as to such identifying information. None of the other
documents or attachments appear to be financial records or contain personally identifying
information. The Court will therefore deny Plaintiff’s motion without prejudice. If there is a
particular document already filed in the record that Plaintiff contends should be filed under seal or
portions of it redacted from public view, she may file another motion identifying the specific
document and explaining why that particular document should be filed under seal or why portions
of it should be redacted.
IT IS THEREFORE ORDERED that Plaintiff’s Request to Seal Records in Equity (ECF
No. 5) is denied without prejudice.
A copy of this Order shall be mailed to Plaintiff.
IT IS SO ORDERED.
Dated October 31, 2025, at Kansas City, Kansas.
Teresa J. James
U.S. Magistrate Judge
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