Laatz v. Zazzle, Inc.

Background

Plaintiff Nicky Laatz filed an administrative motion asking the court to consider whether materials designated by Defendants should be sealed. The motion was filed in connection with Laatz’s motion for relief from a magistrate judge’s nondispositive pretrial order. Defendants filed a statement supporting the sealing request. Laatz did not submit a response.

Legal standard

The court explained that judicial records generally carry a strong presumption of public access. But records attached to motions that are not related, or are only tangentially related, to the merits of a case are subject to the lower “good cause” standard under Federal Rule of Civil Procedure 26(c). That standard requires a particularized showing of specific harm or prejudice from disclosure. The court also discussed the Northern District of California’s local requirements for sealing requests.

Discussion and ruling

The court determined that the motion concerned a challenge to a nondispositive pretrial order and was only tangentially related to the merits of the action. It therefore applied the good-cause standard. The court agreed that the designated information concerned subject matter that it had previously allowed to be sealed and granted the parties’ sealing request for the reasons stated in its prior order.

The court ordered redactions to the highlighted portions of Plaintiff’s motion for relief from the nondispositive pretrial order, identified as ECF No. 320 and the corresponding portions of ECF No. 319-2. The sealing motion was granted.