Sandstrom v. Charter Communications, Inc.
- Eric Tostrud
- 0:24-cv-03118
- U.S. District Court · District of Minnesota
- 3
In Sandstrom v. Charter Communications, Judge Foster granted Charter’s motion to seal documents and required redacted refiling after dismissal.
Charter Communications, Inc. must comply with the redacted-refiling requirement, and the Clerk of Court must seal the specified filings. The order limits public access to those documents.
What happened
In Sandstrom v. Charter Communications, Inc., Charter asked to seal documents it had filed without redactions in connection with its motion to dismiss. Charter said the documents contained confidential, proprietary information, and Mark Sandstrom did not object. Sandstrom had already voluntarily dismissed the case before the court ruled on the motion to dismiss.
The court explained that judicial records generally are presumed open to the public, but that presumption can be overcome. Because the case was dismissed before the motion to dismiss was decided, the documents had not materially contributed to the court’s exercise of judicial power. The court found that Charter’s concern about harm to its business interests was enough to justify sealing them.
Judge Dulce J. Foster granted Charter’s motion. She directed the Clerk of Court to seal ECF Nos. 32, 33, 34, and 40, and required Charter to separately refile redacted versions of ECF Nos. 32 and 40 by January 24, 2025. If Charter failed to do so, the court would order the Clerk to unseal ECF Nos. 32 and 40.
The detailed version
- Sandstrom v. Charter Communications, Inc. · No. 0:24-cv-03118
- Eric Tostrud
- Jan. 3, 2025
Background
Charter Communications, Inc. moved to file documents under seal. The documents—ECF Nos. 32, 33, 34, and 40—had been filed in connection with Charter’s motion to dismiss, but Charter inadvertently filed unsealed and unredacted versions. Charter asked the court to seal those documents retroactively and to replace ECF Nos. 32 and 40 with redacted versions, asserting that they disclosed confidential and proprietary information and that continued public access would harm Charter and its subsidiaries and affiliates. Mark Sandstrom did not object.
A footnote states that Sandstrom voluntarily dismissed the case on October 30, 2024, before the district judge ruled on Charter’s motion to dismiss. That dismissal made the motion to dismiss moot.
Legal standard
The court explained that judicial records generally carry a common-law presumption of public access. That right is not absolute. The strength of the presumption depends on the documents’ role in the court’s exercise of its constitutional judicial power and their value to people monitoring the federal courts. When documents did not play a material role in that exercise, the presumption may be overcome by a countervailing reason rather than a compelling reason.
Decision and order
The court concluded that none of the documents played a material role in the exercise of judicial power because Sandstrom dismissed the case before the district judge ruled on Charter’s motion to dismiss. The court therefore applied the lower countervailing-reason standard. After reviewing the documents, it found that Charter’s assertion that public access would harm its business interests supplied a sufficient countervailing reason. The court granted Charter’s motion to file documents under seal.
The order directed the Clerk of Court to seal ECF Nos. 32, 33, 34, and 40. It also required Charter to separately refile ECF Nos. 43-1 and 43-2 as redacted versions of ECF Nos. 32 and 40, respectively, by January 24, 2025. The order stated that if Charter failed to do so, the court would order the Clerk to unseal ECF Nos. 32 and 40.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.