No Sealing of Expired Harassment Restraining Order
The Minnesota Court of Appeals upheld a district court's decision to deny a motion to seal an expired harassment restraining order. The court emphasized the presumption in favor of public access to court records and found that the arguments presented did not outweigh this presumption. The ruling indicates that sealing records requires compelling reasons, which were not demonstrated in this case.
- ▪Akoto sought to seal records of a harassment restraining order that expired over a year prior.
- ▪The district court found no compelling reasons to seal the records, emphasizing public access.
- ▪The appellate court confirmed that the district court properly applied the balancing test regarding access to court records.
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| Original publisher | Reason Magazine |
| Canonical URL | https://reason.com/volokh/2026/06/03/no-sealing-of-expired-harassment-restraining-order/ |
| Publication time | Wed, 03 Jun 2026 12:34:45 +0000 |
| Retrieval time | 2026-06-03T12:47:07.630Z |
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Opening excerpt (first ~120 words) tap to expand
Free Speech No Sealing of Expired Harassment Restraining Order Eugene Volokh | 6.3.2026 8:34 AM From the May 26 decision in Hayne v. Akoto, by Minnesota Court of Appeals Judge Elizabeth G. Bentley, joined by Judges Keala Ede and Lisa Beane: On July 2, 2025, over a year after [a 2022 harassment restraining order against her] expired, Akoto moved to have the record of the case sealed under Rule 4, subdivision 1(e), of the Minnesota Rules of Public Access. In that motion, Akoto asserted that the public accessibility of the HRO records "continue[d] to cause significant harm to [her] personal and professional life," and that it had negatively impacted her "ability to obtain housing, employment, and to rebuild [her] reputation and relationships." … The district court denied Akoto's motion [and…
Excerpt limited to ~120 words for fair-use compliance. The full article is at Reason Magazine.
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