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 to protect his and his family's safety. The court denied the motion, finding that Petitioner failed to present specific facts to overcome the strong presumption of public access to court records.
| 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, which requires a compelling interest supported by specific factual findings to overcome the presumption of public access. The court noted that Petitioner offered only general allegations of risk without specific facts, and that the information had already been public in a prior case. This reasoning is consistent with the cited authorities. |
The order itself: sound — The order is concise but legally sound. It correctly identifies the burden on the moving party and the high standard (compelling interest + specific facts) required to seal records in the Ninth Circuit. The court explicitly addresses the deficiency in the Petitioner's motion (lack of specific facts) and provides additional context (prior public filing) to support the denial. It does not skip any necessary legal steps for this type of 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.: 26-cv-2797-CAB-VET VILLANUEVA, 14 ORDER DENYING MOTION TO Petitioner, 15 SEAL v. 16 CHRISTOPHER J. LAROSE, et al., [Doc. No. 11] 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. 11.] 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, Petitioner’s first habeas petition containing the 9 |}same information was filed on December 19, 2025 and closed on March 5, 2026. See 10 Ramos Villanueva v. LaRose, No. 25-cv-3679-CAB-SBC. The amount of time that this 11 |/information has been public, together with evidence that Petitioner originally filed his 12 || petition in this case with some sealed documents, are relevant considerations that weigh 13 || against sealing the material in this case based on the arguments Petitioner has presented to 14 || this Court. 15 Itis SO ORDERED. 16 ||Dated: August 3, 2026 (GB 17 Hon. Cathy Ann Bencivengo 18 United States District Judge 19 20 21 22 23 24 25 26 27 28