Pacific Steel Group v. Commercial Metals Company
- Haywood Gilliam
- 4:20-cv-07683
- U.S. District Court · Northern District of California
- 3
In Pacific Steel Group v. Commercial Metals Company, Judge Gilliam granted the parties’ revised motion to keep specified sensitive documents under seal.
The parties’ access to specified court documents is affected because documents covered by the revised sealing request will remain sealed, while documents not included in that revised request must be made public. Public access to the court record is also affected.
What happened
In Pacific Steel Group v. Commercial Metals Company, the parties asked the court to seal documents connected to their cross-motions for summary judgment. The court had previously found their first combined request too broad and required a narrower request.
The court applied the higher “compelling reasons” standard because the documents were connected to dispositive motions. It found that the documents contained personally sensitive information, commercially sensitive information, or confidential business information that outweighed the public’s interest in access.
Judge Haywood S. Gilliam, Jr. granted the revised motion to seal. Documents covered by the revised request will remain sealed, while documents included only in the earlier, broader request must be made public by August 19, 2024.
The detailed version
- Pacific Steel Group v. Commercial Metals Company · No. 4:20-cv-07683
- Haywood Gilliam
- Aug. 9, 2024
Background
The court had ordered the parties to combine their pending requests to seal documents into one administrative motion. After reviewing the parties’ first combined request, the court found that it was not narrowly tailored and ordered them to submit a revised request with narrower sealing and redaction proposals. The parties then filed the revised joint omnibus motion to seal.
Legal standard
The court explained that documents connected to dispositive motions—motions that may resolve claims or the case—are generally subject to a “compelling reasons” standard. Under that standard, the party seeking secrecy must identify compelling reasons supported by specific facts that outweigh the public’s interest in access to judicial records. The court also noted that documents connected to nondispositive motions are generally subject to the lower “good cause” standard, which requires a particularized showing of specific harm from disclosure.
Because the documents at issue were connected to the parties’ cross-motions for summary judgment, the court applied the compelling-reasons standard.
Ruling
The court granted the parties’ revised omnibus motion to seal. It found that the documents contained personally sensitive information, commercially sensitive information, or confidential business information, and that these reasons outweighed the public’s interest in viewing the documents.
Under the order, documents covered by the revised motion will remain under seal. Documents included in the parties’ initial, broader motion but not in the revised request must be made available to the public. The court directed the parties to file public versions of those documents on the docket no later than August 19, 2024.
Disposition
The revised joint omnibus motion to seal was granted.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.