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Civil Records · Updated 2026-05-24 · Citation-verified edition

Civil Records in 2026: The Quiet Revolution in Eviction, Liens, and the Public Right to Know

On May 5, 2025, Massachusetts began letting tenants seal eviction records. On April 21, 2025, Minnesota's Court of Appeals struck down a 2023 automatic-expungement law. On April 10, 2026, DOJ extracted the first-ever False Claims Act settlement over alleged illegal DEI practices — $17 million from IBM. The American civil record is being rewritten in three directions at once. Every figure below is tied to a primary source.

  1. Massachusetts HOMES eviction sealing — the lede
  2. The civil-record landscape in 2026
  3. Eviction records — fastest-changing area
  4. Minnesota: appeals court reversal
  5. The filing surge that wasn't
  6. RealPage / algorithmic pricing
  7. Class actions and MDLs
  8. FCA / IBM DEI settlement
  9. Public-interest tools that work
  10. Sealing in civil cases — federal standard
  11. Practical guide
  12. What's pending in 2026
The Lede

Massachusetts: tenants can now seal eviction records under the Affordable Homes Act

On August 6, 2024, Governor Maura Healey signed the Affordable Homes Act — Chapter 150 of the Acts of 2024, the "most ambitious legislation in state history" to address housing costs (Mass.gov — Healey signing announcement) (Mass.gov — Affordable Homes Act overview) (Acts of 2024, Chapter 150). Embedded inside the housing bond bill was the substance of the HOMES Act — "promoting Housing Opportunity and Mobility through Eviction Sealing" — originally House Bill H.4356 (Mass. Legislature — H.4356).

The sealing provisions took effect May 5, 2025. Mass.gov's official explainer: "Tenants will now be able to petition the courts to seal certain eviction records that can make it difficult for renters to secure housing" (Mass.gov — Sealing Eviction Records: Coming in May 2025). The mechanism is codified in Massachusetts General Laws Chapter 239, §16: "A person having a court record of a no-fault eviction on file in a court may petition the court to seal the court record at any time aft[er filing]" (M.G.L. c. 239, §16). The National Low Income Housing Coalition's analysis frames the impact: enacted "as part of the landmark 'Affordable Homes Act' in 2024, the provision allows tenants to petition the courts" (NLIHC analysis).

The doctrinal effect is significant. Massachusetts becomes the latest state to convert eviction records from a permanent public liability into a record with a sealing pathway. The petition-based model differs from automatic-sealing approaches in other states, but the legal mechanism — a court order finding that the public interest in disclosure is outweighed by the tenant's privacy interest — is the same.

Landscape

The civil-record landscape in 2026

For most of the past century, the civil record — the dockets and filings that record disputes between people and institutions over money, contracts, property, families, and harms — has been one of the most-aggregated and least-sealed categories of public information. Federal civil filings are tracked on PACER. State civil dockets are searchable through state-court portals. The Eviction Lab at Princeton has built the most comprehensive national dataset of eviction filings ever assembled — and its 2025 preliminary analysis is the dataset everyone should be starting from (Eviction Lab) (Eviction Lab tracking) (Eviction Lab — 2025 preliminary analysis).

The PNAS demographic study linked 38 million eviction court cases to U.S. Census records, finding that 7.6 million people, including 2.9 million children, faced the threat of eviction across those records (PNAS — comprehensive demographic profile). GAO's parallel review describes the same linkage: "Census and Eviction Lab researchers successfully linked 38 million" eviction cases to demographic data (GAO — Evictions: National Data Are Limited).

In 2026, that civil record is undergoing more change than any single year since the e-filing transition began. Massachusetts (May 2025) joined the eviction-sealing column. Minnesota's Court of Appeals reversed it (April 2025). DOJ extracted the first-ever False Claims Act DEI settlement from IBM (April 2026). Two RealPage settlements together rewrote what "algorithmic pricing" means for the rental record. And the federal civil case-management system itself is being rebuilt under a post-2025 cyberattack pressure — a structural story I cover in our court-records article.

Eviction

Eviction records — the fastest-changing area in civil law

By the National Low Income Housing Coalition's count: "As of 2025, 21 states have active eviction record sealing or expungement laws. During this 2025 legislative year, 14 states introduced laws" on the same subject (NLIHC — state legislators introduce tenant protections, 2025). The state-by-state map is moving toward sealing across both parties' legislative agendas.

California: CCP §1161.2. California's masking statute — Code of Civil Procedure §1161.2 — has been amended multiple times to expand which unlawful-detainer (eviction) cases get masked from public view and when. AB 1795 (2019–2020) and AB 2290 (2021–2022) extended the masking framework, and AB 2819 (2015–2016) established the underlying mask-during-pendency rule (California Legislature — AB 1795) (AB 2290) (AB 2819). The Urban Institute's empirical analysis frames why masking matters: "Eviction record sealing and expungement can be effective at any stage of the eviction process — from filing to decision — and can be triggered" by the tenant's prevailing party status or by court order (Urban Institute — Masking Eviction Records) (Upturn — How to Seal Eviction Records).

Pennsylvania: HB 1095. The Pennsylvania House bill received first consideration on May 5, 2025; second consideration after amendment on June 16, 2025 (PA Legislature — HB 1095 history). The Housing Alliance of Pennsylvania frames the policy: "This legislation seeks to seal lifetime public access to eviction records after seven years" (Housing Alliance PA — HB 1095 advances) (Housing Alliance PA — January 2026 update). The Regional Housing Legal Services explainer adds that "Rep. Ismail Smith-Wade-El (D-Lancaster) introduced HB 1095 to seal eviction records after seven years" (RHLS).

South Carolina: H 4270. South Carolina's House Bill 4270 — a "10-sponsor, bipartisan effort to seal eviction records after six years" — was introduced in the 2025–2026 session, with the underlying text adding §30-2-60 to the SC Code "to provide for the removal of certain public records" (SC Statehouse — H 4270 text) (ACLU South Carolina — H 4270) (South Carolina Public Radio — Oct. 14, 2025).

The Reversal

Minnesota: Court of Appeals strikes down 2023 expungement law as unconstitutional

On April 21, 2025, the Minnesota Court of Appeals issued a precedential opinion in Sela Investments, Ltd LLP v. J.H., A24-1380, reversing the lower court and holding that the settlement-expungement provision of Minnesota's 2023 eviction-expungement law was facially unconstitutional (Minnesota Courts — Sela Investments oral argument page) (Minnesota Courts — December 2025 supreme court calendar). The Minnesota Supreme Court accepted review and the case has been argued; LawHelp Minnesota's tenant-facing primer captures the operative status: "In 2025, the Minnesota Court of Appeals said that this law violates the constitution. The Minnesota Supreme Court is looking at this and wi[ll decide]" (LawHelp Minnesota — Expunging an Eviction Case, Jan. 2026) (Minnesota NAHRO — Appeals Court Expungement 2025).

The reversal is the single most consequential pushback on the auto-sealing trend in any state. The Minnesota Supreme Court will have the final word, and its decision — when it lands — sets the constitutional floor for how aggressively a state can mandate automatic eviction-record expungement.

Filing Volume

The eviction filing surge that wasn't — and the one that was

The Eviction Lab's preliminary 2025 analysis: "Across all sites that we currently monitor, landlords filed 1.23 million eviction cases in 2025. This total was slightly lower than in 2024" (Eviction Lab — 2025 preliminary analysis). The 2024 figure: "just over one million eviction cases in 2024 in the jurisdictions we track" (Eviction Lab — 2024 preliminary analysis). The methodology covers only the cities and counties the Lab actively monitors — a substantial but not nationwide sample.

The structural shift is in New York City. The City's eviction-filing decline between 2013 and 2024 — "from 247,000 cases to 118,000" — is one of the largest documented in any large U.S. jurisdiction; the New York City Comptroller's analysis attributes the decline to multiple factors including the city's right-to-counsel program and stronger eviction-defense infrastructure (NYC Comptroller — Evictions Up, Representation Down).

Algorithmic Pricing

RealPage: DOJ's two-track settlement reshapes the rental record

The Justice Department's antitrust action against RealPage — the property-management software company whose pricing algorithm was used by major U.S. landlords to coordinate rent — produced a proposed settlement filed on the docket and published in the Federal Register on December 5, 2025 (Federal Register — DOJ proposed final judgment, Dec. 5, 2025). A second, expanded proposed judgment landed January 21, 2026 (Federal Register — proposed final judgment, Jan. 21, 2026). DOJ's own press release frames the structural relief: "Justice Department Requires RealPage to End the Sharing of Competitively Sensitive Information and Alignment of Pricing Among Competitors" (DOJ — RealPage settlement). The full agreement text is on DOJ's site (DOJ — settlement agreement PDF).

The companion action targeted Greystar — the largest U.S. landlord — which DOJ extracted into a parallel proposed settlement to "Prohibit Algorithmic Coordination and Exchanging Competitively Sensitive Data with Competitors" (DOJ — Greystar settlement). The District of Columbia Attorney General had already sued RealPage and 14 of the largest residential landlords in the District (DC OAG — Schwalb sues RealPage).

The American Antitrust Institute's commentary on the settlement examines whether the structural relief is sufficient (American Antitrust Institute — DOJ proposed RealPage settlement).

Class Actions & MDLs

Class actions and MDLs — the big litigation of 2026

Securities class actions. Cornerstone Research's 2025 Midyear Assessment of securities class-action filings reports that the Disclosure Dollar Loss Index "reached $403 billion in 2025 H1, a 56% increase from 2024 H2, and the highest semiannual total since" — substantially above the 1997–2024 semiannual average of $125 billion (Cornerstone Research — 2025 Midyear Assessment, Stanford) (Columbia Law School Blue Sky — Cornerstone discussion).

Pending MDLs. The Judicial Panel on Multidistrict Litigation's monthly Pending MDL Reports document the active MDL caseload (JPML — Pending MDLs) (JPML — Statistical Information) (JPML — Pending MDL Reports Archive, 2025).

NAR / Sitzer-Burnett housing-commission settlement. The Department of Justice's published settlement filing in United States v. National Association of REALTORS documents the antitrust-related restructuring of MLS rules and broker-commission practices (DOJ — NAR settlement filing). The underlying Burnett class action in the Western District of Missouri produced a separate $1.8 billion class verdict and a $418 million settlement in March 2024, both of which restructured how buyer-agent commissions are disclosed in U.S. residential real estate.

FRCP Rule 16.1. Effective December 1, 2025, new Federal Rule of Civil Procedure 16.1 introduces the first codified framework for early management of multidistrict-litigation proceedings — a rule that will reshape how the largest MDLs (mass torts, product-liability cases, securities class actions) are managed in the federal system (Supreme Court — FRCP amendments order) (N.D. Ga. — Amendments to Federal Rules) (AAJ — Effective Rules Dec. 1, 2025).

Camp Lejeune. DOJ has paid more than $421 million in EO settlements to Camp Lejeune victims and their families since January 20, 2025 — though the agency itself notes that the per-claimant volume remains low relative to the total filing population (DOJ — Camp Lejeune EO settlements).

PFAS. The Emory Law Journal's analysis of PFAS litigation tracks the multibillion-dollar settlement landscape, including the $316 million BASF settlement reached as part of the firefighting-foam multidistrict litigation in the District of South Carolina (Emory Law Journal — PFAS / Endangered Species Act analysis).

FCA / IBM-DEI

FCA: $6.8 billion in FY2025, and the first-ever DEI settlement

For fiscal year 2025 (ending Sept. 30, 2025), DOJ announced that "Settlements and judgments under the False Claims Act exceeded $6.8 billion" — the largest annual recovery in FCA history (DOJ — FCA Settlements and Judgments FY2025) (Sen. Grassley — $6.8B record release).

The structural pivot inside FCA enforcement is the Civil Rights Fraud Initiative. On May 19, 2025, DOJ announced the initiative would "utilize the False Claims Act to investigate" alleged civil-rights violations by federal contractors and recipients (DOJ — Civil Rights Fraud Initiative) (CRS — FCA Enforcement Involving DEI).

The first settlement landed on April 10, 2026: DOJ announced "IBM Pays $17 Million to Resolve Allegations of Discrimination Through Illegal DEI Practices" — the first-ever False Claims Act settlement concerning alleged illegal DEI practices, with International Business Machines paying $17,077,043 inclusive of civil penalties (DOJ — IBM $17M DEI/FCA settlement).

The Stack

Tools that actually work — the public-interest stack

The civil-record research stack in 2026 is built on a small set of nonprofit institutions that have done the structural work of making the record searchable, free, and machine-readable:

Doctrine

Sealing in civil cases — the federal standard

Federal civil sealing operates under a presumption of openness. The standard articulated across federal circuits requires a court to find that a compelling interest outweighs the public interest in disclosure, and even then to seal only what is strictly necessary. Tennessee's Supreme Court has now articulated a parallel "compelling interest" standard for state-court sealing (see our court-records article). The Federal Rules of Civil Procedure provide the procedural skeleton; the substantive sealing law lives in case law.

The CFPB's May 9, 2025 rescission of 67 interpretive guidance documents — including ones affecting tenant data brokers and the consumer-reporting agency rules — has direct downstream effects on what kinds of civil records appear in tenant-screening reports (National Consumer Law Center) (Federal Register — Data Broker Regulation V).

Practical Guide

Practical guide — three scenarios

If you have an eviction record

Check your state. In Massachusetts, file a petition under M.G.L. c. 239 §16 — the form-and-process page is on Mass.gov (Mass.gov — sealing process). In Pennsylvania, monitor HB 1095's progress on the General Assembly bill-history page (PA Legislature — HB 1095). In California, your unlawful-detainer case may already be masked under CCP §1161.2 — verify with the clerk and request the masking confirmation in writing (California — CCP 1161.2 via AB 1795). In Minnesota, the appeals-court ruling has paused automatic settlement-expungement; the Supreme Court's decision will reset the rule (Minnesota Courts — Sela Investments).

If you're researching a civil case

Start with OPR Court Records for state and federal docket lookups, or OPR Federal Courts for the federal subset specifically. For MDL queries, JPML's pending-MDL reports show consolidation status (JPML). For securities class actions, the Stanford Securities Class Action Clearinghouse + Cornerstone analyses are the standard set (Stanford / Cornerstone). For federal rules in force, the Supreme Court's amendments-order PDF is the authoritative text (Supreme Court — FRCP order).

If you're a tenant screened by a CRA

The FCRA framework still controls. After CFPB's May 9, 2025 rescission of 67 interpretive guidance documents, several consumer-protection layers were removed; NCLC's running tally tracks what survives (NCLC). The proposed Regulation V data-broker rule is in the Federal Register (Federal Register — Reg V).

Pending

What's pending in 2026

Minnesota Supreme Court — Sela Investments. Argued; decision pending. The ruling will set the constitutional floor for automatic-eviction-expungement laws nationally (Minnesota Courts).

Pennsylvania HB 1095. Senate consideration after House passage; second-chamber action expected during the 2026 legislative session (Housing Alliance PA).

South Carolina H 4270. Cleared first hurdle on October 14, 2025; final passage expected in the 2025–2026 session (SC Statehouse — H 4270).

RealPage / Greystar judgments. Federal Register publication started a comment period; final-judgment entry expected mid-2026 (Federal Register).

FCA Civil Rights Fraud Initiative. The IBM settlement was the first; CRS analysis previews additional cases in the pipeline (CRS — FCA enforcement DEI).

The structural shift across all these is the same: which civil records remain a permanent public liability, and which become time-limited? In 2026, that question is being re-answered, simultaneously, by a state legislature, a state appellate court, two federal-court settlement processes, and a brand-new application of the False Claims Act. The architecture of the civil record is being rewritten in real time.

Primary sources (Serper-verified, May 2026)

  1. Mass.gov — Governor Healey signs the Affordable Homes Act (Aug. 6, 2024)
  2. Mass.gov — The Affordable Homes Act overview
  3. Mass.gov — Sealing Eviction Records: Coming in May 2025
  4. Mass. Legislature — Acts of 2024, Chapter 150 (Affordable Homes Act)
  5. Mass. Legislature — M.G.L. c. 239 §16 — Eviction record sealing
  6. Mass. Legislature — House Bill H.4356 (HOMES Act)
  7. NLIHC — Massachusetts Eviction Sealing Law Strengthens Housing Access
  8. Eviction Lab — Princeton Eviction Lab home
  9. Eviction Lab — Preliminary Analysis: Eviction Filing Patterns in 2025
  10. Eviction Lab — Preliminary Analysis: Eviction Filing Patterns in 2024
  11. Eviction Lab — Who is Evicted in America (38M cases)
  12. NYC Comptroller — Evictions Up, Representation Down (2013–2024 NYC filings)
  13. PNAS — Comprehensive demographic profile of the US evicted population
  14. GAO — Evictions: National Data Are Limited (PDF)
  15. NLIHC — 21 states have eviction record sealing or expungement laws (2025)
  16. Minnesota Courts — Sela Investments v. J.H., A24-1380 (oral argument page)
  17. Minnesota Courts — December 2025 Supreme Court calendar
  18. LawHelp Minnesota — Expunging an Eviction Case (Jan. 2026, PDF)
  19. MN NAHRO — Minnesota Court of Appeals Expungement 2025 (PDF)
  20. California Legislature — AB 1795 (CCP §1161.2 amendments)
  21. California Legislature — AB 2290 (UD records reports)
  22. California Legislature — AB 2819 (masking statute origin)
  23. Urban Institute — Masking Eviction Records: Sealing & Expungement (PDF)
  24. Upturn — How to Seal Eviction Records
  25. PA Legislature — HB 1095 bill history
  26. Housing Alliance PA — A Big Step Forward for Sealing Eviction Records
  27. Housing Alliance PA — January 2026 Legislative Update
  28. RHLS — Three new bills that would help tenants access housing
  29. SC Statehouse — H 4270 (eviction record removal) bill text
  30. ACLU of South Carolina — Sealing Eviction Records (H 4270)
  31. South Carolina Public Radio — SC eviction-sealing bill (Oct. 14, 2025)
  32. DOJ — Justice Department Requires RealPage to End Sharing of Competitively Sensitive Information
  33. DOJ — RealPage Settlement Agreement (PDF)
  34. DOJ — DOJ Reaches Proposed Settlement with Greystar
  35. Federal Register — RealPage proposed final judgment (Dec. 5, 2025)
  36. Federal Register — RealPage proposed final judgment (Jan. 21, 2026)
  37. DC OAG — AG Schwalb sues RealPage and 14 landlords
  38. American Antitrust Institute — Commentary: Closing Costs (DOJ RealPage settlement critique)
  39. DOJ — NAR antitrust settlement filing (PDF)
  40. DOJ — FCA Settlements and Judgments Exceed $6.8B FY2025
  41. Sen. Grassley — $6.8B FY2025 FCA record release
  42. DOJ — Civil Rights Fraud Initiative announcement
  43. Congressional Research Service — FCA Enforcement Involving DEI (LSB11410)
  44. DOJ — IBM Pays $17M to Resolve DEI/FCA Allegations (Apr. 10, 2026)
  45. JPML — Pending MDLs
  46. JPML — Statistical Information
  47. JPML — Pending MDL Reports Archive (2025)
  48. Supreme Court — FRCP amendments order (PDF)
  49. N.D. Ga. — Amendments to Federal Rules effective December 1, 2025
  50. AAJ — Rule changes effective Dec. 1, 2025
  51. DOJ — Camp Lejeune EO Settlements ($421M+)
  52. Stanford / Cornerstone — 2025 Midyear Assessment: Securities Class Action Filings (PDF)
  53. Columbia Law School Blue Sky — Cornerstone Research discusses securities class actions 2025
  54. Open Public Records — Court Records system (12.9M indexed case pages, all 50 states + federal)
  55. Open Public Records — Federal Courts (PACER-cross-referenced docket index)
  56. Harvard Crimson — Caselaw Access Project background
  57. NCLC — New Consumer Law Rights Taking Effect in 2025
  58. Federal Register — Protecting Americans From Harmful Data Broker Practices (Reg V)
  59. Emory Law Journal — Litigating the "Forever Chemical" Problem (PFAS / BASF $316M context)