What Does “Filed Under Seal” Mean in Court?

Federal court document marked filed under seal beside a judge’s desk

If you have ever looked at a federal court docket and seen the words “Filed Under Seal,” “Sealed Document,” or “Under Seal,” you may wonder what they actually mean.

In simple terms, a document filed under seal is a court filing that is not available for ordinary public inspection. The court restricts access to the document because it contains information that may need special protection.

This does not necessarily mean that the entire lawsuit is secret. In many cases, only one document, exhibit, motion, or portion of a filing is sealed while the rest of the case remains publicly accessible.

For people researching U.S. law, Federal Courts, court procedures, legal rights, and public court records, understanding sealed filings is important because a document appearing on a docket does not always mean the public can read the document itself.

What Does “Filed Under Seal” Mean?

When a document is filed under seal, the court has restricted public access to that document.

For example, a party might file:

A motion under seal
An exhibit under seal
Confidential business information
Sensitive personal information
Certain financial records
Documents containing privileged information
Information involving minors or protected individuals
Sensitive evidence in a criminal proceeding

The precise rules vary depending on the court, type of case, and applicable law.

In federal court, PACER specifically states that sealed documents are not available to the public through PACER.

Is a Sealed Document the Same as a Secret Court Case?

No.

This is one of the most important distinctions.

A case can remain publicly visible while particular documents are sealed.

For example, a public docket might show:

Motion to File Document Under Seal

Sealed Document

The public may be able to see the docket entry while being unable to open the actual sealed document.

Some courts' electronic filing procedures specifically distinguish between the publicly visible docket entry and the sealed PDF itself.

A sealed case, on the other hand, can involve much broader restrictions on public access.

Therefore:

Sealed document ≠ necessarily sealed case.

Why Would Someone File a Document Under Seal?

Courts generally recognize that there are circumstances in which information should not be freely available to the public.

One common reason is privacy.

Federal Rule of Civil Procedure 5.2 requires certain personal identifiers in court filings to be redacted. For example, filings generally may contain only the last four digits of a Social Security number or taxpayer-identification number, the year of an individual's birth, a minor's initials, and the last four digits of a financial-account number.

Rule 5.2 also specifically provides that a court may order a filing to be made under seal without redaction and may later order the document unsealed or require a redacted version for the public record.

Other reasons for seeking protection may include confidential commercial information, sensitive evidence, privacy interests, or information protected by a legal privilege or court order.

However, a party cannot necessarily seal something merely because it would be embarrassing or inconvenient to have it publicly available. The applicable court rules and the judge's determination matter.

Does Filing a Motion to Seal Automatically Make the Document Sealed?

Not necessarily.

The procedure depends on the particular federal court and its local rules.

A party may be required to file a motion asking the court for permission to seal particular material. The judge then decides whether sealing is justified.

Some courts have specific electronic filing procedures for sealed documents. For example, federal court filing instructions may require a filer to use a designated sealed filing event rather than an ordinary filing event.

This means attorneys and self-represented litigants should carefully follow the local rules of the court where the case is pending.

Can the Public See a Sealed Document on PACER?

Generally, no.

PACER provides public electronic access to federal court records, but PACER expressly states that sealed documents, including sealed indictments, cannot be found by the public on PACER.

This can sometimes be confusing because the docket may show that something was filed even though the actual document cannot be opened.

For example, you might see:

Document 45 — Sealed Document

but clicking on the document may not provide the contents.

The existence of the docket entry does not mean the public has access to the underlying sealed material.

Can the Parties See a Document Filed Under Seal?

This depends on the court's order and the nature of the filing.

A sealed document is generally not intended for ordinary public access, but authorized parties, attorneys, court personnel, or other individuals may have access depending on the circumstances.

Some courts have procedures under which attorneys of record receive notice of a sealed filing even though the document itself is unavailable to the general public.

The exact access rules should therefore be determined from the particular court's local rules and orders.

Does “Under Seal” Mean the Judge Has Not Read the Document?

No.

A document can be filed under seal and still be considered by the judge.

In fact, sealing often exists precisely because the court needs to consider sensitive material while limiting public access to it.

The fact that a document is sealed does not by itself mean that the document is irrelevant, unimportant, or rejected.

Can a Sealed Document Become Public Later?

Yes.

A sealed document does not necessarily remain sealed forever.

Federal Rule of Civil Procedure 5.2 expressly provides that a court may later unseal a filing or order the filer to submit a redacted version for the public record.

A court may therefore change the status of a document depending on the circumstances.

For example, information that was sensitive during an ongoing proceeding may become less sensitive after the proceeding ends.

The court's order and applicable rules determine whether and when a sealed document may become accessible.

Can You Ask a Court to Unseal a Document?

In some circumstances, yes.

A person seeking access to a sealed judicial record may need to file an appropriate motion or request with the court.

Whether the request succeeds depends on the applicable law, the reason for the original sealing, the interests of the parties, and the court's assessment of public access.

The U.S. Supreme Court has recognized a common-law right of access to judicial records, but it has also explained that the right is not absolute. Courts retain supervisory authority over their records and may restrict access in appropriate circumstances.

Therefore, “the document is part of a court case” does not automatically mean “everyone has an unrestricted right to see it.”

Why Is There a Public Right to Access Court Records?

Public access to court proceedings and judicial records serves an important function.

Courts are part of the public justice system, and transparency can help the public understand how courts operate.

The Supreme Court discussed this principle in Nixon v. Warner Communications, Inc., explaining that courts recognize a general right to inspect and copy judicial records, while also emphasizing that the right is not absolute.

Courts therefore have to balance public access against legitimate interests in confidentiality and other circumstances that justify restricting access.

This is one reason sealing is generally treated as an exception rather than a simple way to hide unfavorable information.

What Is the Difference Between Sealed and Redacted?

These terms are often confused.

Redacted means information has been removed or obscured from a document before the public version is filed.

For example:

Social Security Number: XXX-XX-1234

A public filing might show only the final four digits.

Sealed means the particular filing or document itself is restricted from public access.

For example:

Exhibit 12 — Filed Under Seal

The public may be able to see the docket entry but not the contents of Exhibit 12.

Sometimes both procedures are used. A party may file an unredacted version under seal and a redacted version publicly.

Federal Rule of Civil Procedure 5.2 expressly allows an unredacted copy to be filed under seal in appropriate circumstances.

What Is a “Motion to Seal”?

A motion to seal is a request asking the court to restrict public access to a particular document or information.

The party asking for sealing generally needs to follow the applicable court rules and explain why sealing is appropriate.

The exact requirements vary among federal courts.

A motion to seal may relate to:

A confidential exhibit
Business or trade information
Sensitive personal information
Privileged communications
Protected evidence
Information covered by a protective order
Other information that the court determines should receive restricted treatment

The judge ultimately decides whether the requested restriction is appropriate under the governing rules and law.

What Happens When a Court Grants a Motion to Seal?

If the court grants the request, the document may remain inaccessible to the general public.

The docket may still contain an entry indicating that the filing exists.

Depending on the court's procedures, the public may see something such as:

“Sealed Document”

while authorized users may have different access rights.

Federal court procedures can differ significantly, so the exact process should always be checked against the rules of the particular court.

What Does “Sealed Indictment” Mean?

A sealed indictment is an indictment that has been kept confidential rather than immediately made available to the public.

This can occur in criminal cases where disclosure before a particular stage of the proceedings could interfere with the administration of justice.

PACER specifically identifies sealed indictments as examples of documents that are not available to the public through PACER.

A sealed indictment should therefore not be confused with an indictment that does not exist.

The indictment may exist in the court's records even though the public cannot access its contents at that time.

Does a Sealed Filing Mean Someone Did Something Wrong?

No.

The phrase “filed under seal” does not itself indicate wrongdoing.

It describes the access status of a court filing.

A sealed document could contain sensitive personal information, confidential evidence, proprietary business information, or other material that the court has determined should not be publicly accessible.

The reason for sealing depends on the particular case.

Can a Journalist or Member of the Public Get a Sealed Document?

Possibly, but not automatically.

Public access to sealed judicial records can depend on the court's rules, the reason for sealing, and whether a person has a legal basis for requesting access.

A journalist does not automatically have greater access simply because the person is a member of the press. The Supreme Court has explained that, in the context discussed in Nixon, the press generally does not have a right to trial information superior to that of the general public.

If someone wants access to a sealed filing, the appropriate procedure may involve contacting the clerk's office or filing a motion with the court.

How Can You Tell Whether a Document Is Sealed?

If you are reviewing a federal docket, look for language such as:

“Filed Under Seal”
“Sealed Document”
“Document Under Seal”
“Sealed Motion”
“Sealed Exhibit”
“SEALED”
“Under Seal”

You may also see a docket entry describing the filing without providing access to the underlying document.

PACER explains that sealed documents are not available to the public through its system.

What If PACER Says You Do Not Have Permission to View a Document?

A lack of access does not necessarily mean there is a technical problem with your PACER account.

Certain categories of federal court records have access restrictions, and sealed documents are one important example.

PACER explains that sealed documents cannot be accessed by the public. Other restrictions can also apply to certain Social Security, immigration, and older criminal case documents.

If you believe you should have access because you are a party or authorized attorney, you may need to contact the appropriate federal court or clerk's office.

Filed Under Seal vs. Confidential

The words “confidential” and “sealed” are not always interchangeable.

“Confidential” may describe information that the parties have agreed or been ordered to treat as private.

“Sealed” generally refers to a court-imposed or court-authorized restriction on public access to a filing or court record.

A protective order may govern confidential discovery material, while a separate court order or filing procedure may govern documents submitted under seal.

Understanding which order or rule applies is important because the legal consequences can be different.

Frequently Asked Questions

What does “filed under seal” mean?

It means a court filing has been placed under restricted access and is generally not available for ordinary public inspection.

Can I see a sealed document on PACER?

Generally, no. PACER states that sealed documents are not available to the public through PACER.

Does a sealed document mean the whole case is sealed?

No. A case may remain public while only certain documents or exhibits are sealed.

Can a judge unseal a document?

Yes. Depending on the circumstances, a court can later modify or remove a sealing restriction. Federal Rule of Civil Procedure 5.2 expressly contemplates later unsealing in appropriate circumstances.

Is a sealed filing evidence of wrongdoing?

No. The fact that a document is sealed does not establish wrongdoing by any party.

Can the public request access to a sealed filing?

In some circumstances, a person may ask the court to unseal or provide access to the record. The court decides under the applicable law and circumstances.

Is a redacted document the same as a sealed document?

No. A redacted document remains publicly available with certain information removed or obscured. A sealed document is generally withheld from public access.

Conclusion

When you see “Filed Under Seal” on a court docket, the simplest explanation is that the court has restricted public access to that particular filing.

It does not automatically mean that the entire case is secret, and it does not mean that anyone involved in the case has done something wrong.

Federal courts recognize an important interest in public access to judicial records, but that access is not unlimited. Courts can restrict access when legitimate interests justify doing so.

For anyone researching Federal Courts, U.S. law, court procedures, legal rights, or PACER records, the key distinction is this:

A document can exist on the court docket without being publicly viewable.

If a filing is marked “Under Seal,” the actual contents may be restricted even though the docket reveals that a filing was made.

For a specific case, always check the court's local rules and the judge's orders because procedures for sealing, accessing, and unsealing documents can vary from one federal court to another.

Sources

PACER – Can I Find Sealed Documents on PACER?
PACER – Sealed Documents FAQ
PACER – What Information Is Available Through PACER?
PACER – Available Court Records
U.S. Courts – Find a Case / PACER
U.S. Courts – Find a Federal Court Case
U.S. Courts – Accessing Court Documents
U.S. Courts – Accessing Court Documents
U.S. Supreme Court – Nixon v. Warner Communications, Inc., 435 U.S. 589 (1978)
Nixon v. Warner Communications – U.S. Supreme Court / GovInfo
Cornell Legal Information Institute – Nixon v. Warner Communications
Nixon v. Warner Communications – Supreme Court Opinion
Fourth Circuit – Privacy Protection / Federal Rule of Civil Procedure 5.2
Fourth Circuit – Privacy Protection Rules

Disclaimer

This article is provided for general educational and informational purposes only. It is not legal advice and does not create an attorney-client relationship. Federal and state court procedures can vary, and the rules governing sealed records may depend on the particular case, court, judge, and applicable law. If you need advice concerning a sealed filing or want to request that a document, be sealed or unsealed, consider consulting a qualified attorney or contacting the appropriate court clerk's office.