Circuit Court of the Eighth Judicial District v. Lee Newspapers, 2014 WY 101

A circuit court closed the proceedings and sealed the case file in a juvenile sexual assault case under Wyo. Stat. Ann. § 6-2-319(a).
The closure occurred before an information or indictment was filed in district court, during the interim preliminary proceedings.
Casper Star-Tribune moved to intervene and later filed a declaratory judgment action after the circuit court sealed records and barred public attendance.
The district court granted summary judgment that § 6-2-319(a) does not require closure of records or proceedings and favored redacted disclosure.
The defendant waived the circuit court preliminary hearing and the case was bound over to district court, potentially mootifying the dispute.
This Wyoming Supreme Court case addresses whether the statute permits wholesale closure or requires redacted, open proceedings and records consistent with First Amendment access.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the case presents a justiciable controversy	Appellees claim transcripts remain unavailable and controversy persists.	Circuit court moots issue by transcripts being available; mootness not cured by public access.	Yes; controversy is justiciable due to public interest and potential transcripts access
Did the circuit court violate the First Amendment by closing proceedings and sealing records	Openness of preliminary hearings and documents is generally required; closure without record findings is improper.	Statute authorizes closure to protect victim/defendant identities; safety considerations justify sealing.	Yes; closure and sealing violated First Amendment; no record-based compelling interests articulated
Did the circuit court correctly interpret § 6-2-319(a)	Statute requires limited disclosure; public records should remain open with redactions rather than wholesale closure.	Statute precludes disclosing victim/actor identity; court lacks authority to disclose under the statute.	No; statute allows redacted/open approach; wholesale closure not constitutionally justified
Authority of circuit court over proceedings and documents during preliminary stages	Circuit court can tailor procedures to ensure compliance with statute and constitution.	Circuit court lacks authority to issue disclosure guidelines beyond statute’s terms.	Circuit court has subject-matter jurisdiction and may issue procedures to balance open access with § 6-2-319(a)

Globe Newspaper Co. v. Superior Court for Norfolk County, 457 U.S. 596 (1982) (open trials serve public interest; supports openness and access)
Richmond Newspapers, Inc. v. Virginia, 448 U.S. 555 (1980) (first recognition of right of access to criminal trials)
Press-Enterprise Co. v. Superior Court (Press-Enterprise II), 478 U.S. 1 (1986) (two-part test for access to judicial proceedings and documents)
Nixon v. Warner Communications, Inc., 435 U.S. 589 (1978) (recognizes general right to inspect public records and judicial documents)
In re Providence Journal Co., 293 F.3d 1 (1st Cir. 2002) (right of access to judicial documents among federal cases)
Antar v. United States, 38 F.3d 1348 (3d Cir. 1994) (public access extends to transcripts and related materials)