context: While we review a district court's decision to seal or unseal documents, or to issue or refuse to issue a protective order, for abuse of discretion, we review de novo any errors of law upon which the court relied in exercising its discretion.
citation_a.signal: see also
citation_a.identifier: 518 U.S. 81, 100
citation_a.parenthetical: "A district court by definition abuses its discretion when it makes an error of law."
citation_a.sentence: See, e.g., United States v. Mejia, 448 F.3d 436, 456-57 (D.C.Cir.2006) (reviewing issuance of protective order de novo rather than for abuse of discretion because court applied incorrect legal standard); United States v. El-Sayegh, 131 F.3d 158, 160 (D.C.Cir.1997) (reviewing decision to unseal guilty plea de novo rather than for abuse of discretion because court’s decision was premised on legal error); see also Koon v. United States, 518 U.S. 81, 100, 116 S.Ct. 2035, 135 L.Ed.2d 392 (1996) (“A district court by definition abuses its discretion when it makes an error of law.”). Here, the district court’s explanations indicate de novo review is appropriate.
citation_b.signal: see
citation_b.identifier: 448 F.3d 436, 456-57
citation_b.parenthetical: reviewing issuance of protective order de novo rather than for abuse of discretion because court applied incorrect legal standard
citation_b.sentence: See, e.g., United States v. Mejia, 448 F.3d 436, 456-57 (D.C.Cir.2006) (reviewing issuance of protective order de novo rather than for abuse of discretion because court applied incorrect legal standard); United States v. El-Sayegh, 131 F.3d 158, 160 (D.C.Cir.1997) (reviewing decision to unseal guilty plea de novo rather than for abuse of discretion because court’s decision was premised on legal error); see also Koon v. United States, 518 U.S. 81, 100, 116 S.Ct. 2035, 135 L.Ed.2d 392 (1996) (“A district court by definition abuses its discretion when it makes an error of law.”). Here, the district court’s explanations indicate de novo review is appropriate.