Toporek v. R. R. Donnelley & Sons Company
- John Tunheim
- 0:24-cv-00008
- U.S. District Court · District of Minnesota
- 3
In Toporek v. R.R. Donnelley & Sons Company, Judge Foster granted continued sealing of exhibits containing confidential personnel and proprietary business information.
The parties, the court clerk, and members of the public seeking access to the listed exhibits are affected. The clerk must keep the exhibits under seal, while the parties’ confidential personnel and proprietary business information remains protected from public access.
What happened
In Toporek v. R.R. Donnelley and Sons Company, the parties jointly asked the court to keep exhibits filed with discovery motions under seal. They said the exhibits contained confidential personnel information, proprietary business information, or both, and that redacting them was impractical.
The court explained that court records are generally presumed accessible to the public, but that presumption can be overcome by a sufficient confidentiality interest. It found that these exhibits did not play a material role in the court’s decision on any case-ending motion and that the defendant had a legitimate interest in protecting the information.
Judge Dulce J. Foster granted the joint sealing motion and directed the clerk to keep the listed exhibits under seal. The order addressed only continued sealing of those documents, not the underlying discovery motions.
The detailed version
- Toporek v. R. R. Donnelley & Sons Company · No. 0:24-cv-00008
- John Tunheim
- Apr. 25, 2025
Background
The court considered the parties’ Joint Motion Regarding Continued Sealing. The motion was filed in connection with Defendant’s motion for a protective order concerning corporate-representative deposition topics and Plaintiff’s motion to compel and for an extension of the discovery deadline. The court stated that the underlying motions addressed the same substantive issues and relied on the same exhibits.
The defendant had filed several exhibits under seal. The parties asked the court to continue sealing all of them because each contained confidential personnel information, proprietary business information, or both. The defendant also filed statements asserting that redaction was impractical.
Legal Standard
The court explained that parties may seal civil-case documents only as authorized by a statute or rule, or with the court’s permission. Judicial records carry a common-law presumption of public access, but that right is not absolute. The court must weigh the public interest in access against the interests served by confidentiality.
The strength of the public-access presumption depends partly on how important the documents are to the court’s exercise of its judicial power and how useful they are to people monitoring the federal courts. For documents that do not materially affect the court’s exercise of that power, a countervailing reason can overcome the prediction that the public will have access.
Analysis
The court reviewed each sealed exhibit and found that the exhibits did not play a material role in the exercise of judicial power or in any dispositive motion in the case. It therefore gave greater weight to the parties’ confidentiality interests.
The court found that each exhibit contained sensitive or proprietary information, confidential personnel information, or both. It concluded that the defendant had a legitimate interest in maintaining confidentiality and that this interest outweighed the public interest in access to the exhibits.
Order
The court granted the parties’ Joint Motion Regarding Continued Sealing. It directed the clerk to keep the documents filed at ECF Nos. 39-1, 39-2, 39-3, 46-1, 46-2, 46-3, 46-4, 51, 51-1, and 51-2 under seal. The order did not decide the underlying motion for a protective order or the motion to compel.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.