United States v. Hodge, 1:23-cr-00195

The United States sought leave to file a supplement to its trial brief under seal in a criminal case in the Northern District of Ohio.
The materials to be filed reportedly contain sensitive, non-public information referenced by the government.
The court was required to balance the parties’ interest in confidentiality against the public’s strong interest in accessing judicial records.
There is a strong presumption in favor of public access to court records, especially in criminal proceedings.
The court must provide specific findings justifying any departure from that presumption and ensure any seal is narrowly tailored.
After review, the court granted the motion to seal, finding sufficient cause based on the sensitivity and type of information involved.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the United States can file a trial supplement under seal	Sensitive, non-public information justifies sealing	Not stated	Court grants motion to seal
Standard for sealing court records	Strong reason required, analysis document-by-document	Not stated	Applies Shane Group standard
Public access versus confidentiality	Confidentiality outweighs limited public interest here	Not stated	Confidentiality prevails
Appropriateness and scope of requested seal	Seal is narrowly tailored to the sensitive documents	Not stated	Seal permitted as tailored

Shane Grp. Inc. v. Blue Cross Blue Shield, 825 F.3d 299 (6th Cir. 2016) (sets high bar and procedural requirements for sealing court records, emphasizing strong public access presumption)
Brown & Williamson Tobacco Corp. v. FTC, 710 F.2d 1165 (6th Cir. 1983) (articulates standard for specific findings required to justify sealing judicial records)
Rudd Equip. Co. v. John Deere Constr. & Forestry Co., 834 F.3d 589 (6th Cir. 2016) (reaffirms court’s independent obligation to justify sealing regardless of parties' agreement)