Gray Media Group, Inc. v. Heather Loveridge

CourtCourt of Appeals for the Fourth Circuit
DecidedSeptember 19, 2025
Docket24-1945
StatusPublished

This text of Gray Media Group, Inc. v. Heather Loveridge (Gray Media Group, Inc. v. Heather Loveridge) is published on Counsel Stack Legal Research, covering Court of Appeals for the Fourth Circuit primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Gray Media Group, Inc. v. Heather Loveridge, (4th Cir. 2025).

Opinion

USCA4 Appeal: 24-1945 Doc: 33 Filed: 09/19/2025 Pg: 1 of 16

PUBLISHED

UNITED STATES COURT OF APPEALS FOR THE FOURTH CIRCUIT

No. 24-1945

GRAY MEDIA GROUP, INC., d/b/a WBTV,

Party-in-Interest - Appellant,

and

CLARENCE DELANO BELTON, JR.,

Plaintiff,

v.

HEATHER LOVERIDGE,

Defendant - Appellee.

On Appeal from the United States District Court for the Western District of North Carolina at Charlotte. Max O. Cogburn, Jr., District Judge. (3:22-cv-00060-MOC-SCR)

Argued: May 7, 2025 Decided: September 19, 2025

Before WYNN, RICHARDSON, and BERNER, Circuit Judges.

Affirmed in part, vacated in part, and remanded with instructions by published opinion. Judge Berner wrote the opinion, in which Judge Wynn and Judge Richardson joined.

ARGUED: Lauren Patricia Russell, BALLARD SPAHR, LLP, Washington, D.C., for Appellant. Steven Andrew Bader, CRANFILL SUMNER, LLP, Raleigh, North Carolina, for Appellee. ON BRIEF: Stephanie H. Webster, CRANFILL SUMNER LLP, Charlotte, USCA4 Appeal: 24-1945 Doc: 33 Filed: 09/19/2025 Pg: 2 of 16

North Carolina, for Appellee.

2 USCA4 Appeal: 24-1945 Doc: 33 Filed: 09/19/2025 Pg: 3 of 16

BERNER, Circuit Judge:

The media play a crucial role in ensuring public access to judicial documents and

records, thereby fostering accountability and transparency. “[T]he public and press have a

qualified right of access to judicial documents and records filed in civil and criminal

proceedings.” Company Doe v. Public Citizen, 749 F.3d 246, 265 (4th Cir. 2014). This

qualified right promotes both the public interest and the integrity of the judicial process.

When the right arises under the First Amendment, each day that passes without disclosure

could constitute a separate and cognizable infringement.

These principles of public access and the role of the media lie at the heart of this

case. Clarence Belton, a North Carolina police officer, sued fellow police officer Heather

Loveridge after she shot him several times during the execution of a search warrant. As

one would imagine, Belton’s and Loveridge’s accounts of what occurred on the night of

the shooting differ markedly. Video footage of the shooting offers a third perspective. Yet

this video footage is unavailable for public viewing because it has been shielded

indefinitely from the media and the public eye by order of the district court.

Appellant Gray Local Media Inc.,1 doing business as WBTV, is a Charlotte-based

television station that seeks access to this video footage. After covering the shooting and

the events surrounding it, WBTV filed a motion to intervene in Belton’s lawsuit and a

motion to unseal the video. After determining that it lacked jurisdiction, the district court

denied WBTV’s motion to intervene. The district court then ruled in the alternative on

1 Gray Media Group, Inc. changed its name to Gray Local Media, Inc. 3 USCA4 Appeal: 24-1945 Doc: 33 Filed: 09/19/2025 Pg: 4 of 16

WBTV’s motion to unseal, denying that motion as well. It concluded that WBTV had no

right of access to the video footage arising under either the common law or the First

Amendment. The district court further ruled that even if WBTV could properly assert a

common law or First Amendment right of access to the video, Loveridge’s right to a fair

trial outweighed any interest of WBTV’s in its unsealing.

We agree that the district court lacked jurisdiction to hear WBTV’s motion to

intervene and affirm the district court’s order denying that motion. We construe WBTV’s

appeal from the district court’s denial of its motion to unseal as a petition for a writ of

mandamus and grant the writ. The district court’s order sealing the video footage violated

the well-established rights of the press and of the public to access judicial documents and

records. We therefore vacate in part and reverse in part the order of the district court and

remand with instructions to unseal the video footage at issue.

I. Background

Clarence Belton and Heather Loveridge both served as law enforcement officers in

North Carolina. Belton worked for the Gastonia Police Department, and Loveridge worked

for the Charlotte-Mecklenburg Police Department. On November 1, 2019, a group of law

enforcement officers including Belton and Loveridge participated in carrying out a search

warrant at the home of a man suspected of trafficking methamphetamine. What happened

inside the residence that night is hotly contested. The parties agree that Belton and another

officer used a battering ram to enter the suspect’s home. There, they encountered a woman

pointing a gun directly at them. Belton and several other agents fired their weapons at the

4 USCA4 Appeal: 24-1945 Doc: 33 Filed: 09/19/2025 Pg: 5 of 16

woman, and Belton fell to the ground during the exchange. Loveridge encountered Belton

crawling on the garage floor and shot at him at least ten times. Although he survived, Belton

sustained serious injuries and his career in law enforcement ended as a result.

Belton filed suit against Loveridge and the City of Charlotte in state court. He

asserted four claims: 1) that Loveridge, in her individual capacity, used excessive force in

violation of Belton’s Fourth Amendment rights; 2) that the City and Loveridge, in her

official capacity, were negligent; 3) that Loveridge, in her individual capacity, committed

assault and battery; and 4) that Loveridge, in her individual and official capacities, engaged

in negligent infliction of emotional distress. Loveridge removed the case to federal court

on the basis of federal question jurisdiction and, following discovery, she moved for

summary judgment.

Loveridge filed a motion to seal several exhibits she submitted in support of her

summary judgment motion and Belton consented to the sealing motion. Those are the

exhibits at issue in this case, and they include video and body camera footage of the

shooting (“video exhibits”). Belton also relied on some of the video exhibits in opposing

Loveridge’s summary judgment motion and he too sought to seal the video exhibits with

Loveridge’s consent.

The governing local rules require motions to seal to state the reasons “why sealing

is necessary and why there are no alternatives to filing under seal.” W.D.N.C. Local R.

6.1(c)(2). Neither Loveridge’s nor Belton’s consent motion comported with these rules.

Indeed, the motions did little more than merely restate the requirements for sealing an

exhibit, with nary an explanation as to how these requirements were met. The district court

5 USCA4 Appeal: 24-1945 Doc: 33 Filed: 09/19/2025 Pg: 6 of 16

referred the matter to a magistrate judge who granted the consent motions and ordered the

video exhibits placed under seal.

In September 2023, the district court denied Loveridge’s motion for summary

judgment, and Loveridge timely appealed the district court’s denial of her motion for

summary judgment to this court. In February 2025, a different panel of this court vacated

the district court’s denial of Loveridge’s motion for summary judgment and remanded the

case back to the district court. Belton v. Loveridge, 129 F.4th 271, 279–80 (4th Cir. 2025).

Thus, WBTV’s petition is the only matter currently pending before this court.

While Loveridge’s appeal was pending before this court, Gray Local Media, Inc.

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Gray Media Group, Inc. v. Heather Loveridge, Counsel Stack Legal Research, https://law.counselstack.com/opinion/gray-media-group-inc-v-heather-loveridge-ca4-2025.