Chavez v. Allstate Northbrook Indemnity Company

Summary

The United States District Court for the Southern District of California denied without prejudice Plaintiff’s motion to file documents under seal in support of her opposition to Allstate’s motion for summary judgment. The court held that the compelling-reasons standard applied and found that the parties had not provided particularized, fact-supported reasons or narrowly tailored redactions sufficient to justify sealing the exhibits and opposition brief.

Holdings

1. Because documents filed in connection with a motion for summary judgment are more than tangentially related to the merits, a party seeking to seal them must satisfy the compelling-reasons standard rather than the good-cause standard.
2. A party seeking to seal judicial records must overcome the strong presumption of public access by articulating particularized, compelling reasons supported by factual evidence, and the request must be narrowly tailored to the portions warranting protection.
3. The motion to seal Plaintiff's exhibits and redacted opposition brief was denied without prejudice because the parties failed to make a particularized, evidence-supported showing of compelling reasons and failed to propose adequately targeted redactions.

Questions Presented

1. What standard governs a request to seal documents filed in connection with a motion for summary judgment?
2. Whether Plaintiff and Allstate made the particularized, evidence-supported and narrowly tailored showing necessary to overcome the public's presumptive right of access to the exhibits and redacted opposition brief.

Disposition

other