John Doe v. State of Idaho, 290 P.3d 1277

In 1990, Doe was charged with battery with the intent to commit rape and forcible sexual penetration; he pleaded guilty to the battery charge and the other offense was dismissed.
The district court imposed a unified six-year sentence with two years fixed; Doe was paroled in 1994 and later released from sex-offender registration in 2006 after a finding he posed no reoffense risk.
In 2010, Doe moved to seal the criminal case file under Idaho Court Administrative Rule 32(i) claiming economic harm from public access.
At the hearing, the State did not oppose sealing; the district court orally denied relief, stating the rule does not preclude disclosure of a defendant’s prior conviction and that economic harm could result from crime.
Doe drafted an order for signature reflecting the ruling; he appealed arguing the court abused its discretion by misapplying Rule 32(i).
The appellate court vacates the district court’s order and remands for reconsideration consistent with the opinion, clarifying the rule permits sealing in this context and requires a finding balancing privacy versus public disclosure.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether Rule 32(i) authorizes sealing a criminal file for a convicted defendant based on economic harm	Doe argues Rule 32(i) allows sealing for any interested party including a convicted defendant.	State contends Rule 32(i) does not apply to sealing records for a convicted criminal.	Yes, Rule 32(i) authorizes it; district court erred in denying relief.
Whether the district court failed to make required findings balancing privacy versus public disclosure	Doe contends the court must determine if privacy outweighs disclosure.	State argues no explicit predominance finding was needed?	The court must make explicit findings balancing interests; remand for proper findings.
Whether the district court's reasoning about economic harm was legally correct	Doe asserts economic-harm justification falls within Rule 32(i)(3).	State argues that harm from a conviction is not within the contemplated interests.	Economic harm evidence falls within Rule 32(i)(3); district court erred in narrowing scope.

State v. Turpen, 147 Idaho 869 (Idaho Supreme Court 2009) (motion to seal under Rule 32; court remanded for proper rule application; recognized Rule 32 governs sealing.)
State v. Gurney, 152 Idaho 502 (Idaho Supreme Court 2012) (district court weighed public interest; court satisfied finding of predominance; dissents discuss scope.)
State v. Watkins, 148 Idaho 418 (Idaho Supreme Court 2009) (standard for reviewing discretionary sealing decisions.)
State v. Hedger, 115 Idaho 598 (Idaho Supreme Court 1989) (guide on applying statutory/rule-based privacy and public-disclosure standards.)