Court Rules That Party Not Entitled to Unsealing of Juvenile Delinquency Records of a Witness

In the case of M.M., a minor v. Lion Tamer, LLC, No. 2025-CV-4113 (C.P. Lacka. Co. Sept. 18, 2026 Nealon, J.), the court addressed a Motion by the Defendant seeking to unseal the records relating to the juvenile delinquency proceedings involving a minor identified as “B.S.”

According to the Opinion, this case arose out of a premises liability incident. The Defendant operates an indoor trampoline park. The minor female Plaintiff, M.M., was allegedly lured into a foam pit by a 13 year old teenage boy during which the minor was allegedly sexually assaulted.

The court noted that the Plaintiff did not take any position on the Defendant’s Motion to Unseal Records regarding the juvenile delinquencies proceedings involving a minor identified as B.S.

In reviewing the Motion, the court referred to §6307(a) of the Juvenile Act. 42 Pa. C.S.A. §6307(a).

The court additionally also reviewed Rule 160(A) of the Pennsylvania Rules of Juvenile Court Procedure. Pa. R.J.C.P. 160(A).

The Defendant sought access to B.S.’s juvenile records as a party having a legitimate interest in the proceedings. In making the Motion, the Defendant conceded that it could not find any case law directly on point specifically involving a Defendant in a civil case seeking to have a juvenile criminal record unsealed. 

However, Judge Nealon uncovered relevant case law both at the appellate and trial court level. Based upon the case law found, Judge Nealon ruled that the Defendant could not be deemed a party “having a legitimate interest in the proceedings” under the above-referenced Rules as that language has been construed as referring to parties having a legitimate interest in the juvenile court proceedings.

Judge Nealon also noted that, while Subsection (b) of §6307 of the Juvenile Act was added after certain case law and permitted disclosure of limited information from juvenile delinquent proceedings for certain violent criminal conduct committed when the juvenile at issue was 14 years old or older, the individual in this case was only 13 at the time of the incident. As such, the court found that §6307(b) could not serve as a basis for unsealing the requested juvenile records.

Overall, the court in this case decided that based upon the limited record before it as submitted by the parties, the requested juvenile records of B.S. were protected from public access by the above-cited Rules. Accordingly, the Defendant’s Motion to Unseal the Juvenile Delinquency Documents was denied.

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