In Re Estate of Juanne Jennings Thompson, 636 S.W.3d 1

B. Ray Thompson Jr. and Juanne Thompson created revocable living trusts and a separate 2009 “G-10 Trust” for their grandchildren; both decedents died testate and much of their assets passed via trusts.
Juanne filed a Petition to Set Aside alleging fraudulent transfers to B. Ray Jr.’s trust; the parties later settled (Consent Agreement) and sought court approval.
Co-heirs moved the chancery court to file estate records under seal; the court entered a blanket protective order sealing financial and related filings and closing hearings.
A different faction of family members (including appellant Nicole Thompson) moved to intervene and to unseal the records; the trial court denied intervention and left several documents sealed (Affidavit of Will, Petition to Set Aside, Consent Agreement and Final Judgment, and Removal Documents).
This Court remanded for document-specific findings; on remand the trial court re-affirmed the seal citing privacy and minor-children interests. The Court of Appeals reversed the denial of intervention and reversed the sealing of the listed documents, remanding for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
1) Permissive intervention to challenge protective order	Nicole Thompson: she may permissively intervene because challenging the seal raises legal questions common to the main actions (Tenn. R. Civ. P. 24.02).	CVT/AST/RTP: intervention would cause undue delay and prejudice to the original proceedings.	Reversed trial court. Intervention to challenge a protective order should have been allowed; denial was not justified as causing undue delay.
2) Whether the trial court properly sealed court-filed documents and which standard applies	Thompson: documents filed in the public record (settlement, pleadings) are presumptively open; sealing requires a compelling interest narrowly tailored to that interest.	CVT/AST/RTP: Ballard’s “good cause” analysis for protective orders applies; privacy, minors, and substantial assets justify seal.	Reversed trial court. For non-discovery, dispositive, or court-filed pleadings the correct standard is a compelling interest narrowly tailored; appellants did not meet that burden for the listed documents, so sealing was improper.

Ballard v. Herzke, 924 S.W.2d 652 (Tenn. 1996) (articulates Rule 26.03 good-cause factors for sealing discovery-produced materials).
Kocher v. Bearden, 546 S.W.3d 78 (Tenn. Ct. App. 2017) (public’s qualified right of access; compelling-interest standard applies to sealing non-discovery court records; right to intervene to challenge seals).
Brentwood Acad. v. Doe, 578 S.W.3d 50 (Tenn. Ct. App. 2018) (applies compelling-interest test and narrow tailoring for sealing/redacting court records containing sensitive information).
In re NHC–Nashville Fire Litig., 293 S.W.3d 547 (Tenn. Ct. App. 2008) (distinguishes protective orders over unfiled discovery and discusses court authority over records).
Doe ex rel. Doe v. Roman Catholic Diocese of Nashville, 154 S.W.3d 22 (Tenn. 2005) (defines abuse-of-discretion review and stresses careful scrutiny when access rights are involved).
Shane Group, Inc. v. Blue Cross Blue Shield of Mich., 825 F.3d 299 (6th Cir. 2016) (public access to judicial records is important; sealing decisions receive less deference).
Nixon v. Warner Communications, Inc., 435 U.S. 589 (U.S. 1978) (common-law right of access to judicial records is qualified, not absolute).
Tennessean v. Metro. Gov’t of Nashville, 485 S.W.3d 857 (Tenn. 2016) (reaffirms presumption of openness of courts and records).