Washington v. McEnroe
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Defendant Joseph T. McEnroe sought a court order to seal documents that would have been used in support of a separate motion (his separate motion asked that he be tried second, following his codefendant’s severed trial). Before doing so, he filed a motion to waive Local General Rule (LGR) 15 and requested the opportunity to withdraw those documents in the event his motion to seal was denied. The trial court denied his motion, ruling that General Rule (GR) 15 and its local counterpart precluded withdrawal. The issue before the Washington Supreme Court therefore concerned the proper determination of the proper procedure when a party files documents contemporaneously with a motion to seal. Upon review, the Court held that LGR 15, as written, does not apply to criminal proceedings and that GR 15 does not require documents submitted with a motion to seal to be open to the public while the court considers the motion. Further, the Court held that GR 15 allows withdrawal of those documents if the trial court denies the motion to seal. Accordingly, the Court reversed the trial court and remanded with instructions to allow withdrawal in the event Defendant’s request for sealing was denied.
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