Wesley Smith, et al. v. Officer M. Wheat, et al.

Summary

The United States District Court for the Eastern District of California ruled on the parties’ stipulated request to file exhibits under seal in Smith v. Wheat. The court granted sealing for exhibits involving institutional security and images of the decedent’s final moments, but denied without prejudice requests covering entire deposition transcripts, expert reports, and a notice of adverse action because the requests were not narrowly tailored.

Holdings

1. Documents filed with the court may be sealed when the requesting party demonstrates compelling reasons, including a substantial institutional-safety risk from disclosure of correctional-facility security materials or a serious invasion of privacy from disclosure of images depicting a decedent's final moments.
2. A sealing order must be narrowly drawn and may seal only the portions of the record for which a compelling reason exists; a request to seal entire deposition transcripts or expert reports is improper when it does not distinguish confidential material from material that may be publicly filed.
3. The request to seal the notice of adverse action was denied because the parties failed to identify a compelling reason for sealing it.

Questions Presented

1. Whether the parties had shown compelling reasons to seal exhibits containing correctional-institution security information and images of the decedent's final moments.
2. Whether the stipulated request was narrowly tailored when it sought to seal entire deposition transcripts and expert reports.
3. Whether the parties had shown a compelling reason to seal the notice of adverse action.

Disposition

other