Summary
This United States District Court order grants the defendants' motion to file the plaintiff's medical records under seal in connection with a motion for summary judgment. Applying the Ninth Circuit's compelling reasons standard, the court determined that protecting sensitive health information outweighs the public's right of access to judicial records. Consequently, the exhibit containing the plaintiff's medical history and care details was approved for sealing.
Topics
Practice areas
Questions Presented
- Which standard governs Defendants' motion to seal an exhibit filed in support of a motion for summary judgment?
- Whether the sensitive medical information in the exhibit establishes a compelling reason to seal the exhibit.
Holdings
- The compelling-reasons standard applies to a motion to seal documents filed in connection with a motion for summary judgment because such documents are more than tangentially related to the merits of the case.
- Sensitive medical records may be sealed when the need to protect medical privacy constitutes a compelling reason that outweighs the public's need for direct access to the records.
Key quotations
“The choice between the two standards depends on whether the documents proposed for sealing accompany a motion that is “more than tangentially related” to the merits of the case.” (at 1)
“Therefore, Defendants’ motion to seal, (ECF No. 46), is GRANTED.” (at 2)
Factual background
Defendants sought to file an exhibit consisting of Plaintiff's medical records in support of their motion for summary judgment. The exhibit contained sensitive health information, medical history, and information concerning Plaintiff's care.
Procedural history
In this prisoner civil-rights action, Defendants sought to file an exhibit containing Plaintiff's medical records under seal. The district court applied the compelling-reasons standard because the exhibit accompanied a summary-judgment motion and granted the motion to seal.