Kasso v. City of Minneapolis

Background

Leila Kasso sued the City of Minneapolis and the City of Minneapolis Police Department, alleging employment discrimination. Kasso was representing herself. The defendants had previously asked the court to keep two documents permanently sealed: one because it contained information about a defendant’s medical condition, and the other because it contained allegations of employee misconduct that had not resulted in final discipline. The court granted that request and stated that the sealing order would become final on November 22, 2024, unless a timely filing was made.

Kasso filed a document titled “MOTION for No Sealing Temporary or Permanent” on November 16, 2024. Because she filed it within the deadline and asked that the documents not remain permanently sealed, the court construed it as a motion for further consideration under Local Rule 5.6(f).

Procedural Requirements

The court explained that a motion for further consideration is a nondispositive motion governed by Local Rule 7.1(b). That rule required Kasso to schedule a hearing and file materials including a hearing notice, memorandum of law, exhibits or affidavits, a meet-and-confer statement, and a proposed order. The court also noted that an unrepresented party must provide a certificate concerning the memorandum’s word-count limits. The court found that Kasso’s filing lacked, among other things, a hearing notice and a meet-and-confer statement. It stated that it would have been within its discretion to deny the motion for failure to follow the procedural rules.

Sealing Analysis

The court also reached the merits of Kasso’s request. It recognized a common-law right of public access to judicial records, but explained that this right is not absolute and must be balanced against legitimate confidentiality interests. The court determined that the sealed portions of both documents contained information about a person’s medical condition. It found that the information was highly private and sensitive, and that the interest in keeping those details confidential outweighed the public’s right of access.

The court therefore determined that Docket Numbers 94 and 111 should remain sealed. Because it resolved the issue based on the medical information, it did not decide whether the allegations of employee misconduct in Docket Number 94 also supported continued sealing.

Disposition

The court DENIED Kasso’s Motion for No Sealing Temporary or Permanent, ordered that Docket Numbers 94 and 111 remain SEALED, and left prior consistent orders in full force and effect. The order also stated that violations could lead to appropriate remedies or sanctions, including costs, fines, attorney’s fees, limits on evidence, striking pleadings, dismissal with prejudice, or default judgment.