UNITED STATES OF AMERICA v. UNDER SEAL
US Court of Appeals for the Fourth Circuit, Floyd, April 5, 2017,
Standing- A juvenile whose records were to be disclosed to adult co-defendants had standing to appeal a decision under 18 USC 5038 to release those records protected by the JJDP.

Facts: Juvenile was allegedly involved in gang-related murder in Virginia. When transfer to adult federal jurisdiction was denied, the feds dismissed voluntarily and gave him back to the state to prosecute. They also moved to disclose information about the juvenile to his adult co-defendants as potential Brady material, but the juvenile objected. The information was ordered to be disclosed and the adult co-defendants requested a material witness warrant for him.

Under the modern collateral order doctrine, “an appealable collateral order must ‘[1] conclusively determine the disputed question, [2] resolve an important issue completely separate from the merits of the action, and [3] be effectively unreviewable on appeal from a final judgment.’”

“a nonparty [may] appeal a district court’s order or judgment when the appellant (1) possessed ‘an interest in the cause litigated’ before the district court and (2) ‘participated in the proceedings actively enough to make him privy to the record.’