Summary
The court partially grants and partially denies the defendant’s motion to file exhibits under seal in opposition to the plaintiff’s motion to remand. The court denies sealing a health benefit plan but permits sealing a confidential administrative services agreement and claims data containing sensitive health information.
Topics
Practice areas
Questions Presented
- Whether the defendant established sufficient grounds to seal each of three exhibits filed in connection with its opposition to the plaintiff's motion to remand.
- Whether the interests favoring nondisclosure of the administrative services agreement and health claims data outweighed the public's common-law right of access to judicial records.
Holdings
- A court considering a request to seal judicial records must balance the public's common-law right of access against the interests favoring nondisclosure, with a strong presumption in favor of public access.
- The request to seal the 2023 health benefit plan was denied because the document did not appear to contain personally identifiable information or trade secrets, and the defendant did not articulate harm from public disclosure.
- The request to seal the 2023 administrative services agreement between the defendant and UMR, Inc. was granted.
- The request to seal the health claims data was granted because disclosure could reveal sensitive medical information about a nonparty child, and the resulting privacy interests outweighed the public's interest in access.
Key quotations
“Judicial records are public records. And public records, by definition, presume public access.” (Order)
“In exercising its discretion to seal judicial records, the court must balance the public’s common law right of access against the interests favoring nondisclosure.” (Order)
“The presumption however gauged in favor of public access to judicial records is one of the interests to be weighed on the public’s ‘side of the scales.’” (Order)
“courts should be ungenerous with their discretion to seal judicial records.” (Order)
Factual background
Defendant sought to seal its 2023 health benefit plan, a 2023 administrative services agreement with non-party UMR, Inc., and claims data concerning a relevant plan member. The defendant represented that the administrative services agreement was confidential, contained pricing information, and could cause adverse consequences if disclosed. The claims data contained protected health information concerning a child who was not a party to the litigation.
Procedural history
The defendant filed a motion to seal three exhibits attached to its response opposing the plaintiff's motion to remand. The district court granted the motion as to a confidential administrative services agreement and health claims data, but denied it as to the health benefit plan.