Estate of Gene B. Lokken, The v. UnitedHealth Group, Inc.

Background

This putative class action concerns allegations that the defendants improperly denied medical-insurance claims for medically necessary care based on artificial-intelligence models. The order did not decide those allegations or the pending motions to dismiss.

The parties filed a joint motion asking the court to continue sealing memoranda and exhibits submitted in support of the defendants’ motions to dismiss the original and amended complaints. The parties agreed that the materials should remain sealed because they contained confidential medical information. Publicly filed redacted versions of the memoranda were available, but the parties stated that redacting the exhibits was impractical.

Court’s analysis

The court explained that judicial records generally carry a common-law presumption of public access, but that access is not absolute. The court must balance the public’s interest in access against legitimate confidentiality interests. It found that all of the materials at issue contained sensitive personal health information. It also noted that the materials supporting the original motion had not played a role in the district judge’s exercise of judicial power because that motion had not been decided. Although the later materials were likely to be considered when ruling on the pending motion to dismiss the amended complaint, the court found good cause to keep them sealed because the parties had filed appropriately redacted versions publicly.

Ruling

Judge Dulce J. Foster granted the parties’ Joint Motion Regarding Continued Sealing. The clerk was directed to keep ECF Nos. 22, 25-1 through 25-9, 43, and 46-1 through 46-28 under seal. The order resolved only the sealing issue; it did not rule on the defendants’ motions to dismiss or the merits of the claims.