Brown v. Adamson

Brown · United States District Court for the District of Nevada · December 11, 2024 · No. 3:21-cv-00500-MMD-CSD

Summary

This federal district court order grants motions filed by both parties to seal medical records submitted during briefing on a motion for summary judgment. Relying on Ninth Circuit precedent, the court determines that safeguarding patient medical privacy outweighs the public's right of access to judicial documents. Accordingly, the court approves the sealing of the requested health information.

Court
United States District Court for the District of Nevada
Writing for the Court
Craig S. Denney
Jurisdiction
United States District Court for the District of Nevada
Decision date
December 11, 2024
Docket number
3:21-cv-00500-MMD-CSD
Procedural posture
The court considered cross-motions by Plaintiff and Defendants to file medical records under seal in connection with briefing on Defendants' motion for summary judgment.
Precedential value
unpublished district court order
Disposition
other

Topics

summary judgmentevidencecivil procedure

Practice areas

civil procedureevidenceprisoner civil rights

Questions Presented

  1. Whether the parties established compelling reasons to seal medical records that were more than tangentially related to the merits of the case.

Holdings

  1. Medical privacy constitutes a compelling reason to seal medical records that are more than tangentially related to the merits when the plaintiff's interest in keeping sensitive health information confidential outweighs the public's need for direct access to the records.

Key quotations

“more than tangentially related to the merits of a case,”
the need to protect medical privacy qualifies as a "compelling reason" for sealing records because the plaintiff's interest in keeping his sensitive health information confidential outweighs the public’s need for direct access to the medical records.

Factual background

The parties sought to file Plaintiff's medical records under seal while briefing Defendants' motion for summary judgment. The records contained sensitive health information, and the court determined that they were more than tangentially related to the merits of the case.

Procedural history

In this prisoner civil-rights action, the parties sought to seal medical records submitted in connection with summary-judgment briefing. The district court granted both sealing motions.

Court Document

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