McLaughlin v. Tesla, Inc.
- Susan Van Keulen
- 5:22-cv-07849
- U.S. District Court · Northern District of California
- 4
In McLaughlin v. Tesla, Judge Van Keulen granted Tesla’s motion to seal four transcript lines containing confidential business information about crashes.
Tesla, the plaintiffs, and members of the public seeking access to the hearing transcript.
What happened
In McLaughlin v. Tesla, Inc., Tesla asked to seal about four lines from a hearing transcript. The lines involved discussions about crashes involving Tesla-manufactured cars and Tesla’s business practices concerning those crashes.
Judge Van Keulen applied the stricter standard requiring compelling reasons because the transcript concerned a motion about which state’s law would apply to substantive issues in the case. The court found that the excerpts contained nonpublic business information that could cause competitive harm, were only marginally relevant to the case, and covered a very small portion of the 82-page transcript.
Judge Susan Van Keulen rejected the plaintiffs’ objections and granted the motion to seal. The Clerk must keep the transcript under seal, and Tesla must file a public version with its proposed redactions by November 21, 2024.
The detailed version
- McLaughlin v. Tesla, Inc. · No. 5:22-cv-07849
- Susan Van Keulen
- Nov. 14, 2024
Background
The parties appeared at a September 5, 2024 hearing on motions concerning the exclusion of two expert witnesses and whether Virginia law should apply to certain substantive issues. After the hearing transcript was filed, Tesla moved to seal about four lines in which plaintiffs’ counsel discussed crashes involving cars manufactured by Tesla and Tesla’s business practices regarding those crashes. Plaintiffs opposed the motion.
Sealing standard
The court explained that judicial records generally carry a strong presumption of public access. Because the excerpts related to a choice-of-law motion that was more than tangentially connected to the case’s merits, Tesla had to show “compelling reasons” for sealing them rather than the less demanding “good cause” standard.
Court’s analysis
The court found that the excerpts referenced nonpublic, confidential information about Tesla’s business processes concerning car crashes. Plaintiffs’ counsel confirmed that the information came from discovery. The court concluded that disclosure could harm Tesla’s competitive standing and that compelling reasons supported sealing.
The court acknowledged that the excerpts described the information only at a high level of generality, which weighed against sealing. But the information had little relevance to the substantive issues and did not influence the court’s resolution of the choice-of-law questions. The request also covered only about four lines out of an 82-page transcript, so restricting access would withhold only a small amount of information while protecting Tesla’s asserted competitive interests.
The court rejected plaintiffs’ argument that the motion was untimely. It explained that the transcript deadlines cited by plaintiffs concerned the redaction of specified categories of information, such as birth dates and the names of minor children, and did not prevent a later motion to seal other information. The court also agreed that Tesla’s factual support was thin but found it sufficient for the reasons stated.
Disposition
Judge Susan Van Keulen granted the motion to seal. The Clerk must maintain Docket 106 under seal. Tesla must file a publicly available copy of the transcript containing its proposed redactions by November 21, 2024.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.