Michael Barfield v. Case Confidential
The Fifth DCA quashed a trial court's orders sealing an entire residential eviction court file that had been closed by stipulation of the landlord and tenant. The court held that a non-party member of the public has standing to challenge a closure order and that the litigants' names and matters inherent to a civil eviction proceeding are not subject to a reasonable expectation of privacy justifying closure under Rule 2.420(c)(9)(A)(vi), with no record support for closure under subsection (c)(9)(A)(i).
Key facts
- A landlord, Shorehouse TIC I LLC, filed a residential eviction action in Duval County Court against a tenant for alleged nonpayment of rent; the tenant responded that rent had been paid in full, and the parties then settled with dismissal with prejudice and an 'account credit surplus' for the tenant.
- With the landlord's consent, the trial court granted the tenant's motion to seal the entire court file under Florida Rule of General Practice and Judicial Administration 2.420(c)(9)(A)(i) and (vi).
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Holdings
- A non-party member of the public and the news media have standing to challenge a court order closing or sealing judicial records, consistent with the constitutional right of access under…
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Why it matters
This written opinion reinforces the strong presumption of public access to judicial records in Florida and confirms that non-party members of the public have standing to challenge sealing orders, even those entered by… — full analysis with a trial
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