Luis Antonio Ramos Villanueva v. Christopher J. Larose, et al.
- Proceeding
- district
- Area
- civil
- Panel
- Cathy Ann Bencivengo (author)
Analysis
Petitioner Luis Antonio Ramos Villanueva moved to seal or redact portions of his habeas corpus case records, arguing that disclosure of his identity and location posed a safety risk to him and his family. The Court denied the motion, finding that Petitioner failed to meet the burden of showing a compelling interest supported by specific facts to overcome the presumption of public access.
| What the court decided | The model |
|---|---|
Motion to Seal Denied“For the following reasons, the Court DENIES the motion to seal.” | agree with court The court correctly applied the Ninth Circuit's standard for sealing records, which requires the proponent to demonstrate a compelling interest supported by specific factual findings. The order recites that the petitioner offered only general allegations of risk without specific facts and notes that the case had already been closed and public for several months. Therefore, the denial follows logically from the cited legal standard and the recited record. |
The order itself: sound — The order is concise but legally sufficient. It correctly identifies the applicable standard from binding Ninth Circuit precedent (Kamakana) and applies it to the specific facts recited in the order (lack of specific facts, prior public exposure, and prior pro se filings). It does not skip any necessary legal steps for a standard sealing motion.
Opinion
1 2 3 4 5 6 7 8 9 10 UNITED STATES DISTRICT COURT 11 SOUTHERN DISTRICT OF CALIFORNIA 12 13 LUIS ANTONIO RAMOS Case No.: 25-cv-3679-CAB-SBC VILLANUEVA, 14 ORDER DENYING MOTION TO Petitioner, 15 SEAL v. 16 CHRISTOPHER J. LAROSE, et al., [Doc. No. 18] 17 Respondents. 18 19 20 Petitioner Luis Antonio Ramos Villanueva has moved to seal or redact portions of 21 this habeas case that “contain[] information identifying Petitioner’s name, current place of 22 detention and other identifying information.” [Doc. No. 18.] Petitioner generally argues 23 that disclosure of this information “creates a substantial risk to Petitioner’s personal safety 24 and to the members of his family.” [Id. at 1–2.] For the following reasons, the Court 25 DENIES the motion to seal. 26 There is a general principle in favor of public access to federal court records. Nixon 27 v. Warner Commc’ns, Inc., 435 U.S. 589, 597 (1978). “[T]he proponent of sealing bears 28 the burden with respect to sealing. A failure to meet that burden means that the default 1 || posture of public access prevails.” Kamakana v. City & City of Honolulu, 447 F.3d 1172, 2 || 1182 (9th Cir. 2006). Where a party seeks to bar the public from accessing a litigation 3 document in connection with a dispositive motion, this presumed right can be overcome if 4 ||closure serves a compelling interest supported by specific factual findings. /d. at 1178-79. 5 The Court has considered the reasons advanced by Petitioner and concludes those 6 reasons do not compellingly outweigh the strong presumption in favor of access to public 7 |\\records. Petitioner has not presented specific facts supporting a general allegation of risk 8 his or his family’s safety. Moreover, this case was filed on December 19, 2025 and 9 ||closed on March 5, 2026. The amount of time that this information has been public, 10 || together with evidence that Petitioner filed at least one other habeas petition pro se with 11 ||sealed documents, see Ramos Villanueva v. LaRose, No. 26-cv-2797-CAB-VET, are 12 ||relevant considerations that weigh against sealing the material in this case based on the 13 arguments Petitioner has presented to this Court. 14 It is SO ORDERED. 15 || Dated: August 3, 2026 & 16 Hon. Cathy Ann Bencivengo 17 United States District Judge 18 19 20 21 22 23 24 25 26 27 28