Opinion
99-cr-324 (JSR)
12-14-2022
UNITED STATES OF AMERICA v. RHONDA WHITE, Defendant.
ORDER
JED S. RAKOFF, U.S.D.J.
In a letter dated November 1, 2022 (here attached), pro se defendant Rhonda White moved to seal her conviction in the abovecaptioned case. In Ms. White's letter, she states that her criminal record has prevented her from obtaining jobs and housing assistance.
The Government responded in a letter to the Court dated December 6, 2022 (also attached). The Government argues that the Court lacks subject matter jurisdiction to consider Ms. White's letter motion. The Government cites Doe v. United States, 833 F.3d 192 (2d Cir. 2016), which considered a similar set of facts and held that the district court lacked subject matter jurisdiction over a motion to seal or expunge the defendant's criminal conviction. Doe held that the Federal Rules of Criminal Procedure only provide limited jurisdiction over specific categories of post-judgment motions, and a motion to seal a valid criminal conviction after several years does not fall into any of these categories. Id. at 196. Doe also held that a district court lacks ancillary jurisdiction to seal a valid criminal conviction solely on equitable grounds. Id. at 198.
Regrettably, Doe is controlling. Thus, the Court hereby denies Ms. White's letter motion for lack of subject matter jurisdiction.
SO ORDERED.