Randle v. Ramsey County

Background

Darien Randle sued Ramsey County and other defendants over his claim that officers violated his constitutional rights by using excessive force during his detention at the Ramsey County Jail. During discovery, defendants produced video footage under a court protective order and marked it confidential. Randle moved to remove those designations.

Randle said he wanted to use the videos with medical and mental-health professionals treating injuries from the incident, non-attorney consultants, prospective attorneys, and the public. Defendants opposed disclosure to non-attorney consultants and the public. They argued that the videos reveal the jail’s layout, security-camera locations, and camera blind spots, creating security risks, and that some footage shows uninvolved detainees whose privacy could be harmed. Defendants agreed to allow disclosure to attorneys and healthcare providers who complied with the protective order, and they agreed that one video could be de-designated.

Court’s analysis

The court applied Federal Rule of Civil Procedure 26(c), which allows protective orders limiting discovery disclosures when specific facts show protection is needed. After reviewing the videos, the court found that jail-security concerns supported the confidentiality designations and that portions of the footage implicated detainees’ privacy interests.

The court also distinguished confidentiality during discovery from permanent sealing of materials filed with the court. If a confidential video is later filed as an exhibit or in support of a motion, the parties must follow the procedures in Local Rule 5.6, including temporary sealing, a public redacted version when feasible, and a joint motion if continued sealing is sought.

Ruling

The court granted in part and denied in part Randle’s Motion to Unseal Confidential Evidence. It ordered defendants to provide Randle with the video named “ACC Export 2019-04-24 01.59.02 PM” without its confidential designation. It modified the protective order to allow Randle to disclose confidential videos to his Pro Se Project attorneys and to prospective or retained counsel in the action, provided they review the protective order and the court’s order and sign the required nondisclosure agreement.

The court also allowed disclosure to licensed medical or mental-health providers treating Randle for injuries related to the allegations, subject to the same review and signed nondisclosure agreement. The motion was denied in all other respects, so the order did not permit disclosure of confidential footage to other individuals, including the public or non-attorney consultants. Judge Dulce J. Foster’s order addressed discovery confidentiality and did not resolve the merits of Randle’s excessive-force claim.