Yates v. Sonoma County

Background

Plaintiff Zachary Yates filed an administrative motion to seal a declaration from counsel. The declaration supported an administrative motion to continue the case management conference.

Legal standard

The court explained that documents connected to dispositive motions—motions that could resolve the case—generally require “compelling reasons” to overcome the public’s presumptive right of access. Documents connected to nondispositive motions—motions that do not resolve the 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 that would result from disclosure. The court also noted that the party seeking to seal information must consider reasonable alternatives, limit the material sealed, and explain why less restrictive measures would not be sufficient.

Ruling

The court applied the good-cause standard because the declaration was not associated with a dispositive motion. It found that the declaration contained sensitive information related to Plaintiff’s counsel and his availability. The court also found that the public interest in disclosure was minimal because the information was unrelated to the public’s understanding of the judicial proceedings in the case.

The court GRANTED the administrative motion to file the document under seal. Under Civil Local Rule 79-5(g)(1), the document will remain under seal.