The study found that there is "seldom" a public record of why a sealing was justified, and notes that in cases sealed from the start, "there will almost never be an opportunity for public challenge, because there will be no public record of the case."
The study also found that some courts intentionally leave sealed cases out of the electronic case management and filing system, meaning the public would never know a case was filed. It also notes that it did not count cases with "highly redacted docket sheets" and every document sealed as a sealed case.
Links:http://www.rcfp.org/newsitems/index.php?i=11199
http://www.fjc.gov/public/pdf.nsf/lookup/sealcafc.pdf/$file/sealcafc.pdf
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