United States v. Doe, No. 19-6152 (4th Cir. 2020)Annotate this Case
In explaining defendant's original sentence, the district court's order denying defendant's 18 U.S.C. 3582 motion referred to the government's motion under USSG 5K1.1 based on defendant's substantial assistance.
The Fourth Circuit circuit reversed the district court's denial of defendant's motion to seal the order referring to defendant's assistance, because it was necessary to protect defendant from harm. In this case, defendant's request implicates the public's interest in accessing judicial records, the government's interest in protecting cooperating defendants in federal custody, and defendant's interest in his own safety. Furthermore, the district court ignored facts showing that defendant faces a heightened risk of harm in prison and failed to consider the increased risks that all government cooperators now face due to the advent of electronic filing and the use of the internet to identify cooperators.