Case Citator › Company Doe v. Public Citizen

Company Doe v. Public Citizen

Is it still good law? What later courts have actually done to this case.

Limited by some courts
Court
Fourth Circuit
Citation
749 F.3d 246
Decided
Confirmed treatments
1
Flagged citations read
34 of 34
Citing cases (total)
34
Treatment dates
2024
Limited by some courts
At least one reviewed court has limited this case’s holding to narrower facts or a narrower rule. No reviewed court has overruled it. Company Doe v. Public Citizen was limited on nonparty appellate standing. The Fourth Circuit declined to extend its standing rule to a person who sought access to sealed records only after the original litigation ended.
More on how this was screened

Later courts continue to apply Company Doe's public access and sealing rules. All 34 flagged citations have been read; the confirmed treatment is listed below.

Every treatment on this page is written from the citing opinion itself, with a verbatim quote, never copied from a commercial citator. A citation flagged by our screen but not shown here was read and found not to weaken this case.

34 later cases cite Company Doe v. Public Citizen; 34 of those citations sat close to treatment language and were flagged for reading, and all of them have been read. Citations that did not sit near treatment language were not flagged and were not read one by one, so a court that weakened this case without using any of that language would not appear here.

Relying on Company Doe v. Public Citizen?

This page shows what later courts did to it. Ask about your specific facts and see whether it still carries your argument, with citations you can check.

Treatments

Limited

  • The Fourth Circuit declined to extend Company Doe's nonparty appellate standing rule to a person whose first involvement came after the original case ended.

    Camoin v. Nelnet, Inc. · Fourth Circuit · filed

    Camoin rather contends that he may appeal as a nonparty. Like the nonparty in Doe, Camoin has an interest in the case litigated because he claims a right to access judicial records. 749 F.3d at 261. Yet unlike in Doe, Camoin did not participate in the original sealing proceedings between the parties; he requested to access the documents long after the litigation was over. The second prong of the nonparty appellate standing test asks whether the nonparty has actively participated in the proceedings below such that they are privy to the record. Id. at 259. We have never applied nonparty appellate standing when the nonparty’s only involvement occurred after the original proceedings had terminated. See, e.g., id. at 260; Kenny, 820 F.2d at 668; Under Seal, 853 F.3d at 721–22. Given that this doctrine is an exception to an otherwise bright-line jurisdictional rule, we decline to extend it to this context.
    Read the full opinion on CourtListener →

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