Calderon Jimenez v. Cronen, 1:18-cv-10225

Petitioner Lilian P. Calderon Jimenez filed a 28 U.S.C. § 2241 petition seeking immediate release from ICE detention and a stay of removal pending resolution of her immigration status.
The case was filed in the U.S. District Court for the District of Massachusetts on February 5, 2018, and drew substantial public and media interest.
Federal Rule of Civil Procedure 5.2(c) generally limits remote electronic access to the full docket for non-parties absent a court order; parties and counsel have full remote access.
The court recognized the presumption of public access to judicial records, especially where the government is a party, and the practical difficulty for interested non-parties to obtain records in person.
The court concluded that remote electronic access to the full record should be authorized for all persons, subject to appropriate redactions and sealing procedures for sensitive information.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether non-parties should have remote electronic access to the full case record	Jimenez argued public access and practical barriers justify remote access to full record	Respondents relied on Rule 5.2(c) limits that restrict non-party remote access absent court order	Court ordered full remote access for all persons to the case record, subject to redactions and sealing procedures
Standard for sealing or redaction of filings	Sensitive information should be withheld from public record and can be filed under seal	Government and court stressed Rule 5.2 and case law permit sealing when justified	Court required parties to file motions to seal with redacted public versions when necessary
Timing/limits for seeking reconsideration of access order	N/A (procedural)	N/A (procedural)	Court set deadline: motions for reconsideration due by February 12, 2018
Whether heightened public interest affects access determination	Public interest and government party status favor expanded access	Rule-based privacy protections still apply; redactions possible	Court balanced interests and authorized wider remote access with redaction mechanisms

Nixon v. Warner Commc'ns, Inc., 435 U.S. 589 (1978) (recognizes public right to inspect judicial records)
Anderson v. Cryovac, Inc., 805 F.2d 1 (1st Cir. 1986) (documents relied on in deciding substantive rights presumptively public)
F.T.C. v. Standard Fin. Mgmt., 830 F.2d 404 (1st Cir. 1987) (public access promotes scrutiny where government is party)
In re Continental Illinois Sec. Litig., 732 F.2d 1302 (7th Cir. 1984) (public access fosters accountability of courts and executive)
United States v. Kravetz, 706 F.3d 47 (1st Cir. 2013) (discusses limitations and protections for sensitive information in the public record)