J. v. City and County of San Francisco

Background

The defendants filed an administrative motion to seal exhibits attached to a joint statement concerning discovery of location data. They argued that privacy interests involving C.L. and former plaintiff E.J., together with California law concerning the confidentiality of juvenile case files, supported sealing exhibits containing location data extracted from their phones. The parties later filed a stipulation stating that the plaintiffs agreed the documents should be sealed.

The court noted that a stipulation alone does not establish that documents may be sealed. Neither C.L. nor E.J. filed a declaration identifying a specific privacy intrusion that disclosure would cause.

Legal standard

The public generally has a right to access judicial proceedings. For documents connected only tangentially to the merits of a case, such as the discovery status report involved here, the party seeking to seal material must show “good cause.” That standard still requires a particularized showing of specific harm or prejudice. General allegations of harm are not enough.

Rulings on the exhibits

The court denied the request to seal Exhibits C and F. Those exhibits contained location data derived from E.J.’s image files, presented as a map and a list comparing the data with an earlier production. The court found that the data was materially duplicative of information E.J. had already filed publicly, including timestamps and geolocation coordinates. The court was mindful of the privacy interests of minors who had been detained, especially a non-party such as E.J., but found that these exhibits did not reveal meaningful additional information about E.J.’s location and that it could not identify potential harm from disclosure.

The court also denied the request to seal Exhibit E, which contained location data from C.L.’s phone. The entries generally corresponded to places where C.L. alleged she had been during the events at issue, including Dolores Street, Dolores Park, 17th Street, and the Mission District police station. Although some timestamps did not precisely match C.L.’s allegations, the court found that Exhibit E showed only the same general locations where she claimed to have been and did not create a meaningful privacy intrusion.

The order was titled an order granting in part the administrative motion to file under seal. In the text provided, the court expressly denied sealing Exhibits C, E, and F; it also discussed Exhibits A, B, and D as containing location data from other places in San Francisco and stated that someone familiar with E.J.’s identity might draw privacy-invading inferences from that information.

Next steps ordered by the court

The court gave C.L. and E.J. until January 23, 2025, to file a motion for reconsideration if they believed the court had overlooked harm from disclosure of Exhibits C, E, or F. If no such motion was filed, the defendants were ordered to file those three exhibits in the public record by January 30, 2025.