Jane Doe v. Apple Inc. Health and Welfare Benefit Plan

Summary

The United States District Court for the Northern District of California partially granted and partially denied Jane Doe’s amended administrative motion to seal excerpts of her opposition to a motion to dismiss and a supporting declaration. The court held that compelling reasons supported sealing references that would effectively disclose a confidential settlement agreement or negotiation communications, but found that the proposed redactions were not narrowly tailored where information had already been publicly disclosed. The court ordered revised redacted filings by March 28, 2023.

Holdings

1. A court may seal excerpts of filings that quote from a confidential settlement agreement or refer to the agreement or related negotiation communications so directly that disclosure would effectively unseal the agreement when compelling reasons support protecting the material.
2. A sealing request must be narrowly tailored and supported by a particularized justification; material already disclosed in publicly filed documents is not properly subject to sealing.

Questions Presented

1. Whether Plaintiff demonstrated compelling reasons to seal excerpts of her opposition to Defendant's motion to dismiss and a supporting declaration that quote or refer to a confidential settlement agreement and related negotiations.
2. Whether Plaintiff's proposed redactions were narrowly tailored and supported by a particularized justification, including for information already publicly disclosed.

Disposition

other