Williams v. English et al

UNITED STATES DISTRICT COURT
SOUTHERN DISTRICT OF OHIO
EASTERN DIVISION
CASEY WILLIAMS,
Plaintiff,
v.
THE VILLAGE OF JUNCTION CITY,
et al.,
Defendants.
Civil Action 2:25-cv-1507
Judge Algenon L. Marbley
Magistrate Judge Chelsey M. Vascura
ORDER
This matter is before the Court on Plaintiff’s Motion to Seal Complaint (ECF No. 2).
Plaintiff seeks an order sealing the Complaint because it “contains details about sealed criminal
records, which are confidential under Ohio Revised Code §2953.32(D).” (Id. at 2.) Plaintiff also
asks that “all subsequent pleadings that mention and discuss said sealed criminal records be
accepted for filing under seal.” (Id.)
There is a strong presumption in favor of public access to judicial records. Stanley v.
Turner Oil & Gas Properties, Inc., No. 2:16-CV-386, 2017 WL 5068444, at *1 (S.D. Ohio
July 24, 2017). The Sixth Circuit has directed that documents filed with the Court may be
placed under seal “[o]nly for the most compelling reasons.” Shane Grp., Inc. v. Blue Cross
Blue Shield of Michigan, 825 F.3d 299, 305 (6th Cir. 2016) (quoting In re Knoxville News–
Sentinel Co., 723 F.2d 470, 476 (6th Cir. 1983)). “A movant’s obligation to provide
compelling reasons justifying the seal exists even if the parties themselves agree the filings
should be sealed.” White v. Wilberforce Univ., No. 1:16-CV-1165, 2017 WL 3537233, at *2
Case: 2:25-cv-01507-EAS-CMV Doc #: 7 Filed: 01/02/26 Page: 1 of 3 PAGEID #: <pageID>

2
(S.D. Ohio Aug. 17, 2017) (emphasis in original) (citing Rudd Equip. Co., Inc. v. John Deere
Constr. & Forestry Co., 834 F.3d 589, 595 (6th Cir. 2016)). The proponent of sealing
therefore must “analyze in detail, document by document, the propriety of secrecy, providing
reasons and legal citations.” Shane Grp., Inc., 825 F.3d at 305 (quoting Baxter Int’l, Inc. v.
Abbott Labs., 297 F.3d 544, 548 (7th Cir. 2002)). These reasons and legal citations must be
sufficient for a district court to “set forth specific findings and conclusions which justify
nondisclosure to the public.” Rudd Equip. Co., Inc., 834 F.3d at 594.
Here, Plaintiff’s Motion fails to meet the high standard set forth by the Sixth Circuit,
asserting only that any documents referencing his criminal records (which have already been
sealed by an Ohio court under Ohio Revised Code § 2953.32) should be kept private in federal
court. But Plaintiff himself has placed his criminal record at issue in this case by advancing
claims for retaliatory and malicious prosecution against the officials involved in his prosecution.
Indeed, § 2953.34(A)(4) permits inspection of records sealed under § 2953.32 by “a law
enforcement officer who was involved in the case, for use in the officer’s defense of a civil
action arising out of the officer's involvement in that case.” Defendant Amy English, the Chief of
Police for Junction City, is just such a law enforcement officer. Under these circumstances,
federal district courts have declined to seal documents filed on their own dockets simply because
an Ohio court has sealed criminal records at the state level. See Morrison v. Bd. of Trs. of Green
Twp., 529 F. Supp. 2d 807, 819 (S.D. Ohio 2007), aff’d, 583 F.3d 394 (6th Cir. 2009) (declining
to exclude evidence of criminal records sealed under § 2953.32 on summary judgment); Karl v.
Bizar, No. 2:09-cv-34, 2009 WL 3644115, at *3–4 (S.D. Ohio Oct. 28, 2009) (denying a motion
to seal criminal records that had been sealed under § 2953.32, finding that to adopt the movant’s
argument “would be tantamount to permitting a state court order to override a federal court’s
Case: 2:25-cv-01507-EAS-CMV Doc #: 7 Filed: 01/02/26 Page: 2 of 3 PAGEID #: <pageID>

3
power and discretion to maintain its own records”); Raj Plastic Surgery, LLC v. Raj, No. 1:20-
CV-00751, 2020 WL 4582690, at *2–3 (N.D. Ohio Aug. 10, 2020) (same).
Because Plaintiff relied solely on § 2953.32 as grounds for sealing the Complaint and
subsequent pleadings referencing Plaintiff’s criminal records, and because § 2953.32 does not
provide sufficient grounds to overcome the presumption of public access to federal court records,
Plaintiff’s Motion (ECF No. 2) is DENIED.
IT IS SO ORDERED.
/s/ Chelsey M. Vascura
CHELSEY M. VASCURA
UNITED STATES MAGISTRATE JUDGE
Case: 2:25-cv-01507-EAS-CMV Doc #: 7 Filed: 01/02/26 Page: 3 of 3 PAGEID #: <pageID>