SAUL ADAM LEN
v.
STATE OF FLORIDA
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A trial court does not abuse its discretion in unsealing records previously designated as confidential when the content of the subject matter does not present a privacy interest that overrides the public's right of access, particularly where any injury to third parties results from already publicly available information.
[1] The content of the subject matter of court records determines whether a privacy interest exists sufficient to override the public's constitutional right of access to judi…
[2] A trial court's order unsealing previously confidential records is reviewed for abuse of discretion under the applicable standard of appellate review.
Previewing 2 of 5 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“it is generally the content of the subject matter' that determines whether a privacy interest exists that might override the public's right to inspect the records.”
Establishes the legal standard for determining when privacy interests can override the public's right to access court records.
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Join FLexlaw to unlock all legal intelligenceSaul Adam Len sought to keep sealed certain court records, including a plea colloquy and plea agreement, that had been designated confidential by a pr…
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Third District Court of Appeal
State of Florida
Opinion filed April1, 2026.
Not final until disposition of timely filed motion for rehearing.
No. 3D25-1327 Lower Tribunal No. F24-12790
Saul Adam Len, Appellant,
vs.
State of Florida, Appellee.
An Appeal from the Circuit Court for Miami-Dade County, Zachary James, Judge.
Reizenstein & Associates, P.A., and Philip L. Reizenstein, for appellant.
James Uthmeier, Attorney General, and Liz Marie Feliz, Assistant Attorney General, for appellee.
Before MILLER, LOBREE and BOKOR, JJ.
BOKOR, J.
Saul Adam Len appeals from a trial court order unsealing certain court transcripts and records, including a plea colloquy and a plea agreement, that were sealed by a prior confidentiality order. We review the trial court's order unsealing the records for abuse of discretion.1 Discerning no abuse of discretion, we affirm.
The Florida Supreme Court has explained that “it is generally the content of the subject matter' that determines whether a privacy interest exists that might override the public's right to inspect the records.” Id. at 552 (quoting in part Barron v. Fla. Freedom Newspapers, Inc., 531 So. 2d 113, 118 (Fla. 1988)). The trial court, after an evidentiary hearing, concluded that Len's purported rationale to designate the records confidential “to avoid substantial injury to innocent third parties" did not establish a privacy interest overriding the public's right to inspect the records. Barron, 531 So. 2d at 118; see also Fla. R. Gen. Prac. & Jud. Admin. 2.420(c)(9)(A) (codifying by rule the factors outlined in Barron). The trial court explicitly weighed the public's right to access records and the strong presumption of openness of court proceedings against the purported privacy interests. The trial court found that the release of the information protected by the prior confidentiality order
didn't substantially injure innocent third parties' (Len's wife and family's) privacy interests.2
Such an injury, to the extent it occurred or could occur, was a result of the already publicly available information. So it follows that the content of the subject matter does not present a privacy interest that overrides the public's right to the records. Post-Newsweek Stations, 612 So. 2d at 552. Concluding that the trial court did not abuse its discretion in vacating the previously entered confidentiality order by finding no applicable exception to the interests of judicial accuracy and public access, we affirm.
Affirmed.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Authorities Cited
- Dempsey J. Barron v. Fla. Freedom Newspapers, Inc., 531 So. 2d 113 (Fla. 1988)
- Post-Newsweek Stations v. DOE, 612 So. 2d 549 (Fla. 1992)