Domaine Carneros, Ltd v. Lea Trading LLC
- Beth Freeman
- 5:24-cv-01834
- U.S. District Court · Northern District of California
- 3
In Domaine Carneros v. Lea Trading, Judge Freeman granted two motions to seal personal contact information in an exhibit.
Domaine Carneros, Ltd., Lea Trading LLC, the nonparty declarant whose personal shipping and billing addresses were at issue, and the public’s access to those portions of the exhibit.
What happened
In Domaine Carneros, Ltd. v. Lea Trading LLC, Lea Trading filed two administrative motions involving an exhibit attached to a motion for a sur-reply and to the sur-reply itself. Domaine Carneros asked to seal highlighted portions containing a nonparty declarant’s personal shipping and billing addresses.
The court explained that sealing requests require either compelling reasons or, for records only loosely related to the case’s merits, a specific showing of harm. It found that protecting the nonparty’s personal contact information justified sealing and that the request was narrowly limited.
Judge Beth Labson Freeman granted both administrative motions, ECF Nos. 30 and 34. The order allows the highlighted portions on pages 2 through 8 of the exhibit to be sealed.
The detailed version
- Domaine Carneros, Ltd v. Lea Trading LLC · No. 5:24-cv-01834
- Beth Freeman
- July 23, 2024
Background
The court considered two administrative motions concerning sealed filings: ECF No. 30 and ECF No. 34. Lea Trading LLC filed the motions. Domaine Carneros, Ltd. submitted a declaration responding to each motion and sought to seal the same portions of two identical copies of an eight-page exhibit, identified as ECF Nos. 30-2 and 34-2. The exhibit was attached to Lea Trading’s motion for permission to file a sur-reply and to Lea Trading’s sur-reply.
Domaine Carneros stated that the material contained the personal shipping address and personal billing address of a nonparty declarant. It argued that redacting the information would protect the declarant’s privacy and protect her from harm, and that the requested redactions were narrowly tailored.
Legal standard
The court explained that judicial records generally carry a strong presumption of public access. For records more than tangentially related to the merits of a case, a party seeking to seal them must show compelling reasons that outweigh the public’s interest in disclosure. For records attached to motions that are not related, or are only tangentially related, to the merits, the lower “good cause” standard applies. That standard requires a particularized showing of specific harm or prejudice from disclosure; broad, unsupported allegations are insufficient.
Ruling
The court found compelling reasons to seal the highlighted portions because they contained a nonparty declarant’s personal contact information and disclosure could result in harm. It also found that the request was narrowly tailored.
The court ordered:
- ECF No. 30: GRANTED. - ECF No. 34: GRANTED. - ECF Nos. 30-2 and 34-2: the highlighted portions on pages 2 through 8 may be sealed.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.