Introduction
The Federal Violence Against Women Act (VAWA)
There is a reason Minnesota does not place Domestic Abuse Order for Protection (OFP) and Harassment Restraining Order (HRO) cases on the open internet.
The reason is not administrative convenience. It is personal safety.
Congress enacted the Violence Against Women Act (VAWA) in 1994 to strengthen legal protections, improve access to services, help victims survive domestic and sexual violence, and hold offenders accountable. As the law evolved, Congress expressly addressed a danger that became increasingly obvious in the internet age: a court system should not make it easier to identify or locate a person who sought protection.
Federal law now provides:
“A State, Indian tribe, or territory shall not make available publicly on the Internet any information regarding the registration, filing of a petition for, or issuance of a protection order, restraining order, or injunction … if such publication would be likely to publicly reveal the identity or location of the party protected under such order.”
The danger is not difficult to understand. A protection-order file may identify the person seeking protection, disclose where that person lives or works, describe children or relatives, reveal daily routines, recount allegations of abuse or harassment, or contain intensely private medical and psychological information. Publishing those details online can expose a protected person to renewed contact, retaliation, stalking, humiliation, or other harm. It can also discourage victims from seeking judicial protection in the first place.
VAWA therefore draws a sensible line between information that may be used securely by courts and law enforcement for enforcement purposes and information made freely available to anyone with an internet connection.
Why HRO and OFP Cases Do Not Appear in MCRO
Minnesota Court Records Online (MCRO) is not the same thing as the courthouse record system. MCRO provides remote internet access. Minnesota Public Access Courthouse (MNPAC), by contrast, is accessed through public terminals in courthouses and at the State Law Library.
MCRO’s Terms and Conditions expressly acknowledge that some records available at courthouse terminals cannot lawfully be placed online:
“The following are not available in MCRO, but are available through Minnesota Public Access Courthouse (MNPAC):
Domestic Abuse (OFP) and Harassment Restraining Order (HRO) case types, which the federal Violence Against Women Act (VAWA) prohibits from displaying on the internet.”
The distinction is important. “Public” is not synonymous with “available to the entire world online.” A record that may be inspected under controlled courthouse-access rules does not automatically become a record that Minnesota may publish on MCRO.
The advisory comments to Rule 8 of the Minnesota Rules of Public Access make the same point. They explain that courthouse access and remote internet access are different, and that OFP and HRO proceedings are maintained without remote access as required by 18 U.S.C. § 2265(d)(3).
Minnesota’s rules impose additional protections. Rule 4, subdivision 1(a)(2) restricts public access to HRO proceeding records until the authorized order has been served on the respondent. Rule 4, subdivision 1(f), protects qualifying medical and genetic records filed under a nonpublic cover sheet or filing code. Rule 4, subdivision 1(v), also recognizes records made inaccessible by other court rules, court orders, or applicable law.
These protections are not interchangeable, and they do not all operate in exactly the same way. VAWA addresses internet publication that is likely to reveal a protected party’s identity or location. Minnesota separately regulates courthouse access, remote access, medical records, genetic information, and records protected by court order. Together, however, they reflect a consistent principle: access must account for the safety and privacy interests at stake.
What Defendants Asked the Court to Make Public
That legal framework makes a recent request in our own case especially troubling.
During post-judgment proceedings, Defendants asked the court to redesignate my 2023 petition for a Harassment Restraining Order against Sean C. Stevenson (Rosemount, MN) and the ex parte order granting that petition as public documents. Those records arose from a Dakota County HRO proceeding—the very type of case Minnesota excludes from MCRO because of VAWA’s internet-publication restriction.
The request did not stop with the HRO papers. Sean’s attorney, Ross Tentinger, relied on the HRO proceeding as a reason Sean might need access to confidential medical records produced in our separate civil lawsuit.
At the June 29, 2026 redesignation hearing, Tentinger argued:
“Plaintiff Marie Stevenson brought an HRO against Sean Stevenson in Dakota County. Notably, some of her medical records that were marked confidential in this case were used in that HRO proceeding. And then, based on the protective order, Sean isn’t able to necessarily use some of the records in this case for that defense.”
By then, the HRO petition was nearly three years old. It was not a newly filed proceeding requiring an immediate defense. Yet a proceeding from the summer of 2023 was invoked in 2026 as justification for loosening protection over a lifetime of medical records—and for potentially making those records public.
Those records extended from childbirth, a childhood hospitalization, and a commitment for depression at age sixteen through an intimate female medical examination in 2013. The proposed redesignation was not confined to a particular medical document shown to be necessary for a pending claim. It sought to remove confidentiality from deeply private records spanning decades, under the rationale that Sean might need some of them to defend against an HRO proceeding in the future.
That is not a narrow request tailored to a concrete need. It is an attempt to transform a speculative possibility of future use into a basis for present public exposure.
The Court Was Reminded That Access Has Limits
Our attorney directly addressed the HRO argument at the hearing. The following exchange appears in the transcript at Document 617:
WOLFGRAM: I just wanted to bring up one thing, Your Honor. Mr. Tentinger talks about an HRO; those records are not publicly available. That case is not available. As the Court knows, that those cases, records are very limited, and specifically, medical records are never publicly available in those cases. And the protective orders are covering documents that are received through discovery. Plaintiffs obtained their own medical records. Plaintiffs are able to disclose them as they need to. That doesn’t provide the other party the right to disclose confidential documents that are Plaintiff’s medical records. And if the Court needs that citation, I can find it.
THE COURT: I think I’m good with that.
The distinction our attorney identified is fundamental. My ability to obtain and use my own medical records does not give an opposing party an unrestricted right to disseminate copies obtained through compelled discovery. A litigant does not lose ownership of her privacy merely because she used selected information to seek protection in another proceeding.
Nor should the rules be circumvented by moving HRO documents into a different case file and then asking that they be labeled public there. At a minimum, any request that could result in internet publication of those documents required a direct analysis of VAWA, Minnesota’s remote-access rules, the content of the documents, and the likelihood that publication would identify or locate the protected party. Calling the documents “public” does not perform that analysis.
Our opposition memorandum made the governing protections explicit:
“The Court needs to look no further [than] the Minnesota Rules of Court Access for the non public protections. Medical records, including mental health, are not public. Minn. R. Ct. Access 4, subd. 1(f) (2025). Access to records of harassment restraining order proceedings is limited. Id. at subd. 1(a)(2). Case records that are inaccessible pursuant to court rules and court orders are not public. Id. at subd. 1(v)(2)–(3).”
—Plaintiffs’ Opposition Memorandum, Doc. 598, at 8.
The Candor Problem
Against that background, consider the categorical statement Defendants made in their motion papers:
“The identified court records and discovery documents identified in the accompanying affidavit do not contain trade secrets, competitively sensitive information, private personal information warranting protection, or any other content warranting protection under Minn. R. Civ. P. 26.03.”
—Defendants’ motion papers, Doc. 579.
That assertion is difficult to reconcile with what Defendants were asking the court to redesignate: an HRO petition, an ex parte HRO order, and medical records reaching back to my childhood.
An HRO petition may describe alleged harassment, fear, family relationships, locations, communications, and efforts to obtain protection. Medical records may contain physical-health information, mental-health history, reproductive or gynecological information, diagnoses, examinations, and treatment. Minnesota’s own rules single out both HRO records and qualifying medical records for special treatment. Federal law separately restricts internet publication of protection-order information when it would likely reveal the protected person’s identity or location.
How, then, could these materials be described without qualification as containing no “private personal information warranting protection” and no “other content warranting protection”?
Rule 3.3 of the Minnesota Rules of Professional Conduct imposes a duty of candor toward the tribunal. A lawyer may advocate forcefully, but may not knowingly make a false statement of fact or law, fail to correct a material false statement previously made, or allow the court to be misled by a statement the lawyer knows to be false. The rule’s comments further explain that an assertion made in open court must rest on the lawyer’s knowledge or a reasonably diligent inquiry.
The public record does not allow us to determine an attorney’s subjective knowledge merely from an adverse argument, and disagreement over how a rule applies is not automatically an ethical violation. But the duty of candor supplies the proper standard by which the argument should be examined. It required Defendants to confront the actual character of the documents and the legal protections surrounding them—not erase those features through a sweeping label.
Once HRO documents and decades of medical history were included in the request, the contention that none of the identified materials contained private personal information warranting protection demanded more than repetition. It demanded an explanation. The contrast between the motion’s categorical assertion and the records it covered refutes the premise on its face.
Privacy Protection Is Not Litigation Leverage
VAWA’s internet-publication restriction exists because remote access changes the nature and scale of disclosure. A person reviewing a record at a courthouse terminal is not the same as an unlimited number of people finding, downloading, copying, indexing, and redistributing it online. The internet can turn a sensitive court record into a permanent and searchable instrument of exposure.
That is why MCRO honors the federal restriction. It is not concealing the operation of the courts. It is recognizing that transparency must coexist with safety, privacy, and meaningful access to judicial protection.
The same principle should govern the treatment of records copied into related litigation. A protective order should not become temporary simply because an opposing party can imagine a future use for the documents. Nor should a nearly three-year-old HRO petition become a vehicle for publicly exposing medical history that ranges from childhood trauma to adult female health care.
The question is larger than one motion or one case. If people who ask courts for protection must fear that their petitions, ex parte orders, and medical histories may later be relabeled and published through collateral litigation, the harm extends beyond the individual litigant. It weakens the promise that seeking protection will not itself become a new source of danger.
VAWA recognizes that danger. MCRO recognizes it. Minnesota’s court-access rules recognize it. The duty of candor required Defendants to recognize it too.
This article discusses filings and arguments in court proceedings and expresses the author’s analysis and opinion. Quotations are drawn from the identified court documents and hearing transcript.
