Flagg v. City of Detroit

268 F.R.D. 279, 76 Fed. R. Serv. 3d 1151, 2010 U.S. Dist. LEXIS 51585, 2010 WL 2181481
CourtDistrict Court, E.D. Michigan
DecidedMay 26, 2010
DocketNo. 05-74253
StatusPublished
Cited by20 cases

This text of 268 F.R.D. 279 (Flagg v. City of Detroit) is published on Counsel Stack Legal Research, covering District Court, E.D. Michigan primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Flagg v. City of Detroit, 268 F.R.D. 279, 76 Fed. R. Serv. 3d 1151, 2010 U.S. Dist. LEXIS 51585, 2010 WL 2181481 (E.D. Mich. 2010).

Opinion

OPINION AND ORDER REGARDING MOTION TO UNSEAL RECORD

GERALD E. ROSEN, Chief Judge.

I. INTRODUCTION

In this ease, the Plaintiff children of the late Tamara Greene—through their next friends, Ernest Flagg, Taris Jackson, and Brian Greene—allege that the Defendant City of Detroit, a number of former high-ranking City of Detroit officials, and certain current and former Detroit police officials violated their federal constitutional right of access to the courts by deliberately delaying and obstructing the investigation into the April 30, 2003 murder of Ms. Greene. During the course of a contentious discovery period—which remains ongoing and is set to conclude at the end of July—the parties have filed a number of motions and other materials under seal, and the Court has issued five orders under seal. Nearly all of these sealed filings occurred between mid-December of 2009 and early April of 2010, as the parties entered a particularly intensive phase of discovery and began to depose a number of non-parties.

In a letter to the Court dated March 23, 2010, counsel for the Detroit Free Press has expressed concern that this case “is being litigated almost entirely in secret in contravention of Constitutional requirements.” (Free Press’s 3/23/2010 Motion at 1.) As noted in this letter—and as evidenced by the newspaper articles and other media reports that invariably follow virtually every development or docket entry in this litigation—this case involves matters of “genuine public interest” and a number of “high profile public officials,” (id. at 2), some of whom are parties but some of whom are not. In light of this public interest, the Free Press seeks greater access to the record in this case through the unsealing of all materials on the court docket and the lifting of what it characterizes as an “undocumented gag order,” arguing that the record in its present state violates an asserted “common law right of access to judicial proceedings and records” and a First Amendment “right of access to judicial documents.” (Id. at 3, 5.)

At a hearing held on March 23, 2010 and in a subsequent April 2, 2010 order, the Court directed that the Free Press’s March 23 letter be placed on the docket and treated as a motion.1 In addition, the parties were invited to file briefs setting forth their positions on the Free Press’s request to unseal all of the sealed materials on the docket, and the Free Press filed an April 21, 2010 reply brief in further support of its request. Finally, the Court and counsel, for both the parties and for all interested local media outlets, addressed this matter at length at a May 12, 2010 hearing.

[282]*282As the Court stated at the May 12 hearing, this case has posed a number of challenges, and the Court has expended considerable time and effort in managing the discovery phase of this litigation. Nonetheless, the procedural rules and legal principles that govern the parties and the Court during this discovery period are precisely the same as those that apply in every other case on this Court’s civil docket. Under Federal Rule of Civil Procedure 26(b)(1), civil litigants are afforded broad pretrial discovery, see Lewis v. ACB Business Services, Inc., 135 F.3d 389, 402 (6th Cir.1998), which often results in “extensive intrusion into the affairs of both litigants and third parties,” Seattle Times Co. v. Rhinehart, 467 U.S. 20, 30, 104 S.Ct. 2199, 2206, 81 L.Ed.2d 17 (1984) (footnote omitted). Because of the potentially intrusive nature of discovery, “it is necessary for the trial court to have the authority to issue protective orders conferred by Rule 26(c),” in order to regulate the use and disclosure of information that “if publicly released could be damaging to reputation and privacy.” Seattle Times, 467 U.S. at 34-35, 104 S.Ct. at 2208-09.

The Supreme Court’s reading of Rule 26 in the Seattle Times decision precisely fits the circumstances of this case. On the one hand, this Court has repeatedly emphasized, on the public record, its intent to permit Plaintiffs to pursue as broad a discovery effort as authorized under the Federal Rules of Civil Procedure and the rules of evidence, so that a complete record may be developed for future motion practice and, if necessary, for trial. Under the particular circumstances presented here, this complete course of discovery not only allows Plaintiffs to prosecute their case, but also advances a vital public interest, by shedding light on the actions of public officials who face serious allegations of obstruction of justice. On the other hand— and, again, as the Court has repeatedly explained on the public record—the Court has insisted that the parties conduct their discovery efforts in a manner that does not interfere with the ongoing investigation into the murder of Tamara Greene, and that does not unduly invade the privacy interests of individuals who are not parties, and who, in some cases, are neither public officials nor have anything beyond the slightest (if any) connection to the issues in this case. Throughout the ongoing discovery period in this case, the Court has attempted to navigate a course between these competing concerns, and has endeavored to explain, in as public a fashion as practicable, the decisions it has made and the reasons for these decisions.

As the Court observed at the May 12 hearing, and as set forth in greater detail below, the Free Press’s arguments in support of its motion to unseal the record pay insufficient heed to these basic rules and principles that govern the discovery phase of civil litigation and the concerns that animate this law. In its characterization of the record in this case, the Free Press overstates the nature and extent of the sealed filings on the docket, while understating the justifications provided by the Court for keeping certain materials under seal. In its characterization of the law, the Free Press largely misstates the standards that govern public access to discovery materials. As the Supreme Court has expressly recognized—in a decision which notably is not cited in the Free Press’s submissions, nor in Plaintiffs’ brief in support of the Free Press’s position-—-“restraints placed on discovered, but not yet admitted, information are not a restriction on a traditionally public source of information.” Seattle Times, 467 U.S. at 33, 104 S.Ct. at 2208. The Court’s decisions to maintain certain materials under seal during the ongoing discovery phase of this litigation must be considered against this legal backdrop.

The Court is well aware of, and deeply respects, the vital role served by the media in reporting on the activities and exposing the wrongdoing of public officials. The Court further acknowledges and commends the work done by the Free Press and other local media outlets to expose public corruption and wrongdoing in the City of Detroit. In that same vein, the allegations of this case, if ultimately supported by admissible evidence and proven to the satisfaction of a jury, paint a truly troubling picture of deliberate malfeasance by high-ranking Detroit politicians and law enforcement officials.

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268 F.R.D. 279, 76 Fed. R. Serv. 3d 1151, 2010 U.S. Dist. LEXIS 51585, 2010 WL 2181481, Counsel Stack Legal Research, https://law.counselstack.com/opinion/flagg-v-city-of-detroit-mied-2010.