Summary
The United States District Court for the Southern District of California granted Plaintiff Cherisha Lovejoy’s motion to seal portions of a declaration exhibit filed in support of a renewed motion for class certification. The court held that protecting absent class members’ names, salary information, marital status, and addresses constituted compelling reasons to seal the information, which was not relevant to the class-certification issue. The Clerk was directed to seal the unredacted wage statements lodged at Document 74.
Topics
Practice areas
Questions Presented
- Whether plaintiff demonstrated compelling reasons to seal personally identifying and compensation-related information of absent class members contained in wage statements filed in support of a renewed motion for class certification.
- Whether the requested sealing was narrowly tailored so that relevant information remained publicly accessible.
Holdings
- Protection of absent class members' privacy constitutes a compelling reason to seal their names, salary information, marital status, and addresses in the wage statements.
- The motion to seal was properly narrowly tailored because it withheld only irrelevant personally identifiable information while preserving access to the relevant wage-statement format and employer-identification information.
Key quotations
“In order to overcome this strong presumption, the party seeking to seal a judicial record must “articulate compelling reasons supported by specific factual findings that outweigh the general history of access and the public policies favoring disclosure, such as the public interest in understanding the judicial process.”” (at 2)
“The protection of absent class member privacy is a compelling reason to seal their names, salary information, marital status, and addresses.” (at 3)
Factual background
Plaintiff sought to file portions of thirty-four wage statements in support of a renewed motion for class certification. The requested redactions covered absent class members' names, salary information, marital status, and addresses. The wage statements were offered to show that Transdev issued uniform wage statements across locations, while the personally identifying information was not relevant to the class-certification motion.
Procedural history
Plaintiff filed a renewed motion for class certification and attached the Hewgill Declaration and thirty-four wage statements. Plaintiff moved to seal personally identifying and compensation-related information in those wage statements, and lodged an unredacted version. The court granted the motion and directed the clerk to seal Document 74.