Which judge(s) ruled to keep Donald Trump grand jury materials sealed and what reasons were given?
Executive summary
Two federal judges have separately ruled to keep grand‑jury materials in high‑profile Epstein/Maxwell matters sealed: U.S. District Judge Richard Berman refused a Trump administration bid to unseal Jeffrey Epstein grand‑jury transcripts in August, saying there was clear precedent and no “special circumstance” to justify release [1]; and U.S. District Judge Paul Engelmayer ruled that grand‑jury materials used to indict Ghislaine Maxwell should remain sealed because they “would not reveal new information of any consequence” and unsealing would harm the grand‑jury system [2] [3]. Available sources do not mention any other judges who ruled to keep Trump‑related grand jury materials sealed.
1. Two judges kept Epstein/Maxwell grand‑jury records under wraps
Judge Richard Berman denied the Justice Department’s renewed request to unseal grand‑jury materials in the Epstein matter, writing that longstanding precedent and the purpose of grand‑jury secrecy supported keeping the records sealed and that the government had not shown the materials contained any “special circumstance” warranting release [1]. Separately, Judge Paul Engelmayer refused the government’s motion to unseal grand‑jury materials in Ghislaine Maxwell’s prosecution, concluding that publishing them “would not reveal new information of any consequence” and that invoking a secrecy exception too readily would damage the grand‑jury system [2] [3].
2. Legal reasoning: precedent, comparative value of the materials, and victims’ privacy
Berman emphasized “clear precedent and sound purpose” for secrecy and noted the Justice Department already possessed voluminous Epstein investigative files—roughly 100,000 pages—so the limited grand‑jury testimony (described as some 70 pages) added little that would justify breaking secrecy; he also flagged victim‑safety and privacy concerns, including insufficient notice to victims before the government’s motion [1] [4]. Engelmayer similarly framed the request as failing to serve public knowledge: he wrote the transcripts would add “next to nothing new” and warned that applying unsealing exceptions “casually or promiscuously” would harm the grand‑jury institution [2] [3].
3. How judges weighed the government’s motives and the public interest
Both judges scrutinized the Justice Department’s asserted public‑interest rationale. Engelmayer’s opinion openly questioned whether the administration’s move was genuine transparency or a performative gesture designed to placate political critics, noting the records would not materially change public understanding [3]. Berman also treated the government as the logical party to coordinate disclosures and implied the breadth of materials already held by DOJ diminished any argument that grand‑jury transcripts were uniquely necessary for public scrutiny [1].
4. Procedural faults and victim protections factored in the rulings
Berman singled out procedural shortcomings in the government’s approach, including inadequate notice to victims and concerns over threats to their safety and privacy; he treated those factors as “another compelling reason not to unseal” [1]. Engelmayer’s decision likewise stressed institutional protection: the secrecy exceptions are limited and should not be expanded simply because the case is high‑profile [2] [3].
5. Countervailing developments and the evolving legal landscape
Despite these denials, other actors and laws have sought greater disclosure. Congress passed (and President Trump signed) the Epstein Files Transparency Act directing the DOJ to release unclassified Epstein‑related records within 30 days—an intervention that prompted renewed motions and at least one different judge (Rodney Smith) later concluding the statute overrides Rule 6’s bar on disclosing grand‑jury materials [5] [6] [7] [8]. That legislative development illustrates how statutory changes can shift judicial outcomes even where precedent favors secrecy [8].
6. What this means for transparency advocates and prosecutors
The Berman and Engelmayer orders show federal judges remain protective of grand‑jury secrecy absent clear, narrow grounds for disclosure—especially when extensive investigative files already exist and when victims’ privacy is at stake [1] [2]. At the same time, Congress and other judges have signaled pressure to make Epstein‑era materials public; these competing forces mean outcomes can change quickly depending on new laws or different judicial interpretations [5] [6] [8].
Limitations: available sources cover the Berman and Engelmayer rulings and subsequent legislative action and a later separate ruling by Rodney Smith granting unsealing under the new statute; available sources do not mention other judges issuing orders to keep Trump‑related grand‑jury materials sealed beyond those discussed [1] [2] [5] [6] [7].