In Re in the Matter of the Application of Jason Leopold to Unseal Certain Electronic Surveillance Applications and Orders

CourtDistrict Court, District of Columbia
DecidedDecember 17, 2020
DocketMisc. No. 2013-0712
StatusPublished

This text of In Re in the Matter of the Application of Jason Leopold to Unseal Certain Electronic Surveillance Applications and Orders (In Re in the Matter of the Application of Jason Leopold to Unseal Certain Electronic Surveillance Applications and Orders) is published on Counsel Stack Legal Research, covering District Court, District of Columbia primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
In Re in the Matter of the Application of Jason Leopold to Unseal Certain Electronic Surveillance Applications and Orders, (D.D.C. 2020).

Opinion

UNITED STATES DISTRICT COURT FOR THE DISTRICT OF COLUMBIA

IN THE MATTER OF THE APPLICATION OF JASON LEOPOLD TO UNSEAL Misc. Action No. 13-mc-00712 CERTAIN ELECTRONIC SURVEILLANCE APPLICATIONS AND ORDERS. Chief Judge Beryl A. Howell

MEMORANDUM OPINION AND ORDER

Following issuance, on September 1, 2020, of the D.C. Circuit’s remand mandate, which

directed this Court to “determine . . . how and when greater access can be provided” to certain

sealed investigative applications and related judicial records, in accordance with guidance set out

in In re Leopold to Unseal Certain Electronic Surveillance Applications and Orders

(“Leopold”), 964 F.3d 1121, 1135 (D.C. Cir. 2020), the parties were directed to submit jointly

their proposals for doing so. Minute Order (Sept. 1, 2020). The parties then submitted separate

responses, see Gov’t’s Response to Court’s September 1, 2020 Minute Order Following Remand

from the D.C. Circuit (“Gov’t’s Resp.”), ECF No. 67; Pet’rs’ Response to September 1, 2020

Minute Order (“Pet’rs’ Resp.”), ECF No. 68, which largely focus on what they describe as

“prospective relief,” that is, on new procedures to enable expeditious unsealing of future

applications for warrants issued pursuant to the Stored Communications Act (“SCA”), 18 U.S.C.

§ 2703(a), SCA § 2703(d) orders, pen registers and trap and trace (“PR/TT”) devices, see id.

§ 3123, and foreign requests for use of these investigative authorities, pursuant to Mutual Legal

Assistance Treaties (“MLATs”), see id. § 3512(a)(2)(B)–(C), once those matters are closed. See

Gov’t’s Resp. at 5–13.1 Thus far, the parties have been “unable to propose a workable solution

for historical records.” Id. at 13.

1 Petitioners’ request for unsealing did not originally include MLAT requests, but the government has

1 Although repeatedly expressing opposition to “efforts to grant relief that the petitioners

did not seek,” id. at 2; see also id. at 3–4 (identifying “concessions or limitations made [by

petitioners] during litigation” that should govern the scope of relief on remand); id. at 5

(“urg[ing]” that relief be formulated only “in the context of what petitioners have requested in

this litigation”); id. at 13 (arguing that “[t]he burden of resolving the mandated public disclosure

of historical surveillance orders is lessened by the concessions made by the petitioners during

appeal, during oral argument, and through discussions with the U.S. Attorney[’]s Office”); id. at

19–20 (“The Government will seek to satisfy the demands made by petitioner[s] that were

preserved on appeal as to the historical records together with concessions they made at oral

argument . . . .”), the government simultaneously acknowledges, as it must, that “the [Leopold]

remand appears to be more expansive than what petitioners requested,” id. at 3; see also id. at

10–12 (suggesting that the logic of the Leopold opinion requires historical unsealing of MLAT

requests, even though “petitioner’s request may not have specifically contemplated access to

these records”). Indeed; but the government opted not to seek rehearing or clarification, nor

appealed the Circuit panel’s decision, meaning that the panel’s mandate must be implemented as

is.

The parties’ separate submissions on implementation are unhelpful in several respects.

First, in focusing their responses on “prospective” relief and ignoring, for now, “retrospective”

relief, the parties disregard the bulk of the work, post-Leopold, confronting the parties and the

Court, since “historical” investigative applications are being filed daily and the most recently

filed applications are in ongoing, rather than closed, criminal investigations and thus are not even

indicated that, going forward, they should be unsealed along with SCA warrants, SCA § 2703(d) orders, and PR/TTs, because “arguably they are among the judicial [records] which the D.C. Circuit decision in Leopold intended for eventual public access.” Gov’t’s Resp. at 10.

2 currently subject to unsealing. Further, the prospective process outlined inappropriately shifts

some tasks from the government to this District’s Clerk’s Office, including, for example,

proposing that the Clerk’s Office should shoulder the burden of notifying the government when

an unsealing deadline for a sealed investigative application is coming due so that further

extensions may be sought, if necessary. Second, in at least two respects, the government’s

proposal for unsealing historical investigative records is not compliant with the D.C. Circuit’s

mandate, by suggesting: first, that the panel’s Leopold decision requires that unredacted records

be released; and, second, that disclosure of some historical records will take the form of an

“extraction” of information instead of the records themselves. Finally, the parties fail to propose

specific operational details or any timeline for conducting the massive task of unsealing

historical judicial records at issue. These defects are explained in turn to provide guidance to the

parties in preparing their next joint status report proposing a plan for implementation of the

Leopold mandate in a manner that comports with that mandate.

1. Parties’ Proposed “Prospective Relief”

With respect to “prospective” relief, the parties propose the following. First, the

government will standardize its case captions to exclude personally identifiable information. See

Gov’t’s Resp. at 5–6, 11. This change to case captions has already been accomplished, however,

pursuant to a Memorandum of Understanding entered into by the Clerk’s Office and the U.S.

Attorney’s Office for the District of Columbia (“USAO”), which ensures that standardized case

captions for sealed applications contain no personally identifying information, such as the target

email account, telephone number, or subscriber name. Instead, standardized case captions reflect

some relevant information about the investigative application submitted, including the number of

target telephone lines or email accounts, the types of targets, the service provider that is the

3 recipient of the order, and the statutory violation being investigated. See CLERK’S OFFICE, U.S.

DIST. COURT, D.C. & CRIM. DIV., U.S. ATT’Y’S OFFICE, D.C., MEM. OF UNDERSTANDING:

ELECTRONIC FILING OF CERTAIN SEALED APPLICATIONS AND ORDERS 2 (Aug. 15, 2017),

https://www.dcd.uscourts.gov/sites/dcd/files/MOU_Electronic_Filing_Pen_Registers.pdf; see

also In re Leopold to Unseal Certain Electronic Surveillance Applications & Orders, 300

F. Supp. 3d 61, 104–05 (D.D.C. 2018).2

The only new proposal for case captions is that the standardized caption information

already in effect would be supplemented to include an indication that an application contains

grand jury material and so must remain sealed. See Gov’t’s Resp. at 5–6. This supplemental

information will likely be little used, as the government concedes that “[o]rdinarily, the

Government makes application for electronic surveillance orders without explicit reference to

information obtained by the Grand Jury,” id. at 5, and “such applications do not always have to

rely upon grand jury materials to establish a basis for issuing the requested order,” id. at 6. This

procedure may very well “ease[] the burden upon the Government when trying to identify

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