Doe 1400 v. Stanford Health Care
- Beth Freeman
- 5:24-cv-09359
- U.S. District Court · Northern District of California
- 4
In Doe #1400 v. Stanford Health Care, Judge Freeman denied reconsideration and terminated two related motions.
Doe #1400’s requests for reconsideration, expedited consideration, and permission to use sealed documents were denied or terminated; the existing limited sealing of identifying information remained in place.
What happened
In Doe #1400 v. Stanford Health Care, Doe #1400 asked the court to reconsider its refusal to seal the entire federal-court record. Doe #1400 was concerned that identifying information, including a name, signature, and medical conditions, remained visible in some electronic filing tabs.
The court explained that it had already sealed documents containing Doe #1400’s identifying information and had sealed a document showing part of Doe #1400’s signature. The court found that the reconsideration motion repeated earlier concerns and did not identify a new fact, legal change, or important matter the court had previously overlooked.
Judge Beth Labson Freeman denied reconsideration. The court terminated the motion to shorten time as moot and terminated the request to use two sealed documents in the state-court proceedings, explaining that Doe #1400 did not need the court’s permission to use Doe #1400’s own records.
The detailed version
- Doe 1400 v. Stanford Health Care · No. 5:24-cv-09359
- Beth Freeman
- May 6, 2025
Background
Doe #1400 initially sued Stanford Health Care and unnamed defendants in state court. After amendment and service on Stanford Health Care, Stanford Health Care answered and removed the case to federal court. While the parties litigated Doe #1400’s request to return the case to state court, Doe #1400 also asked the federal court to seal the entire record.
The court later remanded the action to the Superior Court of California for Santa Clara County. The state court documented receiving the remand materials. The federal court had denied the request to seal the entire record but sealed documents containing identifying information about Doe #1400, including information in electronic document tabs. It had also sealed a document showing part of Doe #1400’s signature.
Motion for reconsideration
Doe #1400 moved for reconsideration of the order denying the request to seal the entire record. Doe #1400 expressed concern that identifying information, including a name, signature, and medical conditions, appeared publicly on the docket and in electronic document tabs. Doe #1400 also asked to demonstrate the issue in person using a personal laptop.
Under Federal Rule of Civil Procedure 54(b), a court may revise certain orders before final judgment. The court also applied the requirements of Civil Local Rule 7-9(b), which generally requires a party seeking reconsideration to identify a material difference in facts or law, new material facts or a change in law, or a serious failure to consider material facts or important legal arguments.
The court found that Doe #1400’s motion did not meet those requirements. It repeated the concerns raised in the earlier sealing motion. The court stated that it had already determined that preserving Doe #1400’s anonymity was a compelling reason to seal documents because Doe #1400 is a protected person under California law. The court further explained that Doe #1400, Stanford Health Care, and the court could open and review the sealed documents in their own browser windows, but a general member of the public could not.
Rulings
The court denied Doe #1400’s motion for reconsideration of the order denying the request to seal the entire record.
The court terminated Doe #1400’s motion to shorten time as moot.
The court terminated Doe #1400’s request for an order allowing use of the sealed, redacted versions of two documents in the state-court proceedings. The court stated that Doe #1400 did not need permission from the federal court to use Doe #1400’s own records.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.