Doyle Lee Hamm, a death-row prisoner, challenged Alabama’s lethal-injection protocol under the Eighth Amendment. During that litigation, Alabama provided the protocol to the district court under a protective order. Although the document was never formally filed, the court heard expert testimony about it, considered it at an evidentiary hearing, and relied on it in resolving motions and injunctive relief. After Hamm’s case ended, newspapers and the Associated Press intervened to obtain access to a redacted version. The Eleventh Circuit affirmed. It held that the press had an adequate nexus to the case for permissive intervention because it sought to assert the common-law right of access to a judicial record. The protocol became a judicial record because the district court used it to decide substantive issues, even though it remained confidential and was not formally filed. The district court properly balanced Alabama’s confidentiality interests against the public’s access interest and found no good cause sufficient to overcome that right. The decision is a leading transparency ruling concerning documents relied on in constitutional litigation over execution methods.