Detillion v. Ohio Department of Rehabilitation and Correction, 2:22-cv-02671

Background

Plaintiff, a former ODRC employee, sued ODRC and OCSEA after her termination following an inmate suicide at the Correctional Reception Center; the inmate was believed to be a gang member in an open-bed holding area.
Defendants moved to file under seal or redact numerous exhibits attached to their summary-judgment filings, asserting interests in protecting medical records, personal identifying information, gang/inmate identities and witness statements, and ODRC security protocols.
The court applied the Sixth Circuit seal standard (Shane Group) requiring a compelling interest and narrow tailoring to overcome the presumption of public access.
Plaintiff opposed most sealing requests, relying in part on a recent Ohio Supreme Court public-records decision and arguing prior disclosure negated confidentiality.
The magistrate judge found compelling, narrowly tailored interests for sealing/redaction in most categories (medical/PII, gang/member and inmate-witness IDs, security procedures) but determined OCSEA Exhibits U-56–U-61 (private text messages) lacked a sufficient sealing justification.
Ruling: Motion to seal/manually file is GRANTED in part and DENIED in part; Exhibits U-56–U-61 must be filed unsealed within seven days; remaining sealing and manual filing requests granted.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sealing medical records and third-party health info	Plaintiff: Records were previously produced and not protected; public interest in access	Defendants: Health privacy is a compelling interest; disclosure risks harm/embarrassment	Sealing/redaction of medical records justified and narrowly tailored; permitted
Sealing PII (SSNs, emails) of plaintiff and third parties	Plaintiff: Some info is or should be public; prior production undermines secrecy claim	Defendants: PII risks identity theft and harassment, especially for third parties	Sealing/redaction of PII justified to protect privacy; permitted
Sealing names/identifiers of alleged gang members and inmate-witness statements	Plaintiff: Public-records decision (Sultaana) undermines security exemption; some statements not covered by statute	Defendants: Documents themselves show gang affiliation and security threat; inmate informant/witness exemptions apply; disclosure risks harm	Court: Security and witness-identity interests compelling; redactions permitted; Sultaana distinguished on record-specific grounds
Sealing ODRC security policies/procedures	Plaintiff: Public should be able to assess policy compliance; prior sharing of reports undermines secrecy	Defendants: Detailed security protocols could be exploited by inmates, risking safety	Court: Protection of security details is a compelling interest; redaction or sealing where necessary and narrowly tailored; permitted
Sealing private text messages (OCSEA Exhibits U-56–U-61) labeled AEO	Plaintiff: Sought AEO designation but did not assert broader public-interest basis; messages were previously produced confidentially	Defendants: Relied on AEO designation to justify temporary seal	Court: AEO designation alone insufficient to meet compelling-interest standard; denial to seal these exhibits; ordered them unsealed

Key Cases Cited

Shane Grp., Inc. v. Blue Cross Blue Shield of Mich., 825 F.3d 299 (6th Cir. 2016) (establishes heavy presumption of public access and that only compelling, narrowly tailored reasons justify sealing)
Baxter Int’l, Inc. v. Abbott Labs., 297 F.3d 544 (7th Cir.) (distinguishes discovery-stage confidentiality from adjudicative public record access)
Brown & Williamson Tobacco Corp. v. F.T.C., 710 F.2d 1165 (6th Cir. 1983) (articulates presumption of openness for court records)
United States v. Amodeo, 71 F.3d 1044 (2d Cir. 1995) (instructs that privacy interests of third parties weigh heavily in sealing analysis)
Kondash v. Kia Motors Am., Inc., [citation="767 F. App'x 635"] (6th Cir. 2019) (requires showing that compelling reasons outweigh public interest to seal)