Jefferson (ID 44578) v. Moore, 5:23-cv-03263

Plaintiff Anthony Jefferson brought a case related to use of force at a Kansas correctional facility.
The Kansas Department of Corrections (KDOC), as an interested party, sought to file Exhibit V (a DVD of security video related to the incident) under seal.
KDOC argued that public release of the footage poses safety and security risks for inmates and staff.
KDOC requested the Plaintiff not be given a personal copy but permitted supervised viewing.
Defendants supported KDOC’s motion, citing established practice in similar matters.
The Court considered the presumption of public access to judicial records, weighed against security concerns specific to correctional facility surveillance footage.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Exhibit V (prison surveillance video) should be sealed from public access	Plaintiff did not expressly object; seeks access to evidence for litigation	Security concerns outweigh public access; risk of showing jail surveillance	Motion to seal Exhibit V granted
Whether Plaintiff should possess a personal copy of Exhibit V	Plaintiff seeks access for case preparation	Inmates can view videos under staff supervision only, not have copies	Plaintiff may view, but not receive a copy; supervised access granted
Balancing public interest vs. institutional security	Presumption of open judicial records applies	Institutional safety justifies rare sealing of prison videos	Security interest outweighs presumption; seal is proper
Adequacy of KDOC’s supervised-access policy	Plaintiff seeks reasonable access	KDOC says policy aligns with historic practice, is reasonable	Supervised viewing procedure approved

Colony Ins. Co. v. Burke, 698 F.3d 1222 (10th Cir. 2012) (recognizing common-law right of access to judicial records, but noting presumption is not absolute)
Brown v. Flowers, 974 F.3d 1178 (10th Cir. 2020) (upholding sealing of prison video footage for safety and security as substantial interest)