Eli v. DEA, No. 15-99, 2016 WL 4990179 (D.R.I. Sept. 16, 2016) (McConnell, Jr., J.)
Re: Request for exhibits introduced in third party doctor's trial
Disposition: Denying defendant's motion for summary judgment; granting plaintiff's motion for summary judgment
- Exemptions 6 & 7(C): The court holds that "[t]he records of [the doctor's] trial can . . . be subjected to appropriate public scrutiny with minimal intrusion upon the privacy interests of the third parties." First, the court finds that "the public has an interest in the court records from [the doctor's] trial because it allows the public to know 'what their government is up to' in carrying out its investigative and judicial functions." "Specifically, disclosing the court exhibits allows the public to know what evidence the government had that caused it to tout the indictment of [the doctor] as a 'warning to all medical professionals that if [they] illegally prescribe medications for personal gain [they] will be prosecuted to the fullest extent of the law.'" Second, discussing the privacy interests, the court finds that "[t]he government introduced unredacted copies of previously private medical records into a public trial." "The government never requested that the trial court seal the documents, and it never sought to have personally identifiable information on the documents redacted." "Moreover, it has allowed the trial transcript containing all of the names of the third parties and discussion of their medical conditions to remain available to the public." The court does find that "[i]t is an unfortunate fact that the court exhibits contain intimate details of [other third party] private individuals." However, "the Court finds that it can protect most of the privacy interests of the third parties by excluding personally identifiable information in the exhibits" and "ordering the DEA to redact highly personal information of no consequence to the trial or conviction of [the doctor]." The court finds that "[r]edacting the exhibits in this fashion minimizes the privacy interests implicated; therefore, in this instance, the balance of interests tips in favor of public interest."