Deborah Woods sued the City of St. Louis and other governmental actors in the United States District Court for the Eastern District of Missouri, asserting claims under Title II of the Americans with Disabilities Act and 42 U.S.C. § 1983 for alleged excessive force while confined at the City Justice Center. The Court considered Plaintiff’s motions for continual sealing of medical records and to alter/amend the Court’s prior order denying her a third court-appointed attorney.
Factual Overview
Woods, proceeding pro se, alleged that due to her disabilities and defendants’ failure to accommodate them, she was excluded from participating in public services and programs. She also claimed that while confined at the City Justice Center, St. Louis City officers subjected her to excessive force in violation of the Constitution. Additionally, she brought a Monell claim against the City of St. Louis, alleging deliberate indifference to longstanding problems at the facility.
After the Court scheduled an in-person hearing, Woods filed medical records to support her request to participate virtually. The Court granted her request for virtual participation. Subsequently, Woods moved to have these medical records and any future medical records permanently sealed. Separately, after two court-appointed attorneys withdrew from representing her citing irreconcilable differences, Woods sought appointment of a third attorney.
Legal Analysis
Motion to Seal Medical Records: The Court analyzed Woods’ arguments for sealing under HIPAA, PACER guidelines, and privacy rights. The Court found that HIPAA does not apply to judicial proceedings and therefore provided no basis for sealing. The Court also determined that PACER guidelines do not bind the Court’s decision-making regarding sealed documents. Finally, the Court concluded that Woods’ privacy interest in her medical information did not outweigh the public’s right of access to judicial records, particularly given the records’ relevance to her ADA claims.
Motion for Third Court-Appointed Attorney: The Court examined Woods’ request under the applicable legal standard for appointment of counsel in civil cases. The Court noted that there is no constitutional or statutory right to appointed counsel in civil cases. Despite Woods’ cognitive disabilities and use of a remote assistant for filing documents, the Court found no extraordinary circumstances warranting appointment of a third attorney, particularly given her inability to work with two previous court-appointed attorneys.
The Court denied both Woods’ motion to seal medical records and her motion to alter/amend the prior order denying appointment of a third attorney, but granted her leave to file a motion to withdraw certain medical documents from the public record.
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