UnifySCC v. Cody

Background

Defendant Santa Clara County filed Defendants’ Administrative Motion to Seal on October 1, 2024. The County sought to seal unredacted versions of portions of exhibits identified in the declaration of Bryan K. Anderson. The exhibits had been submitted in redacted form in support of defendants’ objections to plaintiffs’ reply exhibits concerning defendants’ motion for summary judgment. The County stated that the material included employee identifying information, including employee names and personal email addresses. Plaintiffs did not oppose the motion.

Legal standard

The court explained that judicial records generally carry a strong presumption of public access. For records related more than tangentially to the underlying claims, 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 if the information is disclosed.

The court also required compliance with Civil Local Rule 79-5. That rule requires an explanation of the interests supporting sealing, the injury that would result if sealing were denied, why a less restrictive alternative would not be sufficient, supporting evidence where necessary, and a request narrowly limited to material that may properly be sealed.

Court’s analysis

The court found compelling reasons to seal the personally identifying information in the County’s exhibits. The material included names, addresses, phone numbers, and email addresses. It also included employee identification numbers, which the court found could be used to obtain other sensitive information, such as an employee’s income, leave status, exemption status, and vaccination status. The court further found that the personally identifying information was not material to the merits of the motion.

The court determined that the request was narrowly tailored because the County sought to seal only the specified personally identifying information and no other information in the exhibits.

Ruling

Judge Beth Labson Freeman granted Defendants’ Administrative Motion to Seal, ECF No. 162. The order granted sealing for the highlighted portions of the following exhibits:

- ECF No. 93-3, Exhibit 1 to Bryan K. Anderson’s declaration, specifically columns 1 and 2 of the list of class members, containing employee names and identifying numbers. - ECF Nos. 156-10 through 156-15, Exhibits 2 through 7 to the declaration, specifically highlighted portions containing employee names and email addresses.

The order did not state that the entire exhibits were sealed.