U.S. v. Wahi

Dist. Ct. lacked jurisdiction to consider defendant’s motion to expunge judicial record in closed criminal case. While Dist. Ct. had properly followed Seventh Circuit decisions in Flowers, 389 F.3d 737 and Janik, 10 F.3d 470, when finding that it had ancillary jurisdiction to reopen closed criminal case and then to ultimately deny defendant’s motion, under Kokkomen, 511 US 375, ancillary jurisdiction may only be used to reopen closed cases either to permit claims that are factually interdependent with closed matter or to enable court to manage its proceedings and to effectuate its original decree. Moreover, instant motion to reopen closed criminal case to expunge judicial records on purely equitable grounds did not satisfy either limited circumstance identified by Kokkomen Court for reopening closed case. As such, Ct. of Appeals overruled its prior holdings in Flowers and Janik and found that Dist. Ct.'s authority to expunge judicial records must instead have source in Constitution or statutes.