Dubanoski v. Wells Fargo Bank, N.A.
- Nancy Brasel
- 0:23-cv-03606
- U.S. District Court · District of Minnesota
- 4
In Dubanoski v. Wells Fargo, Judge Foster kept sensitive personnel documents sealed and ordered four exhibits unsealed.
Jeanette Dubanoski, Wells Fargo Bank, N.A., non-party employees whose personnel information appears in the documents, and members of the public seeking access to the court filings.
What happened
In Dubanoski v. Wells Fargo Bank, N.A., the court considered the parties’ joint request about documents filed under seal in connection with Wells Fargo’s unresolved motion for summary judgment. The parties agreed that four exhibits could be made public but disagreed about the remaining documents.
Jeanette Dubanoski argued that the remaining documents should also be unsealed because they contained no personal information beyond people’s names. Wells Fargo argued that the documents contained confidential personnel, disciplinary, and business information involving non-party employees. The court reviewed the documents and found that they concerned an internal complaint investigation and sensitive personnel matters.
The court, in an order by Judge Dulce J. Foster, granted the joint sealing motion as follows: it kept eight specified documents under seal and ordered four other documents unsealed. The court noted that its ruling did not determine how the District Judge might treat the documents when deciding later dispositive motions or conducting a trial.
The detailed version
- Dubanoski v. Wells Fargo Bank, N.A. · No. 0:23-cv-03606
- Nancy Brasel
- July 8, 2025
Background
The court addressed the parties’ Joint Motion Regarding Continued Sealing, filed in connection with Wells Fargo’s pending motion for summary judgment. Wells Fargo had filed several exhibits under seal, and Jeanette Dubanoski had also filed several exhibits under seal. The parties agreed that the documents filed at ECF Nos. 46-3, 46-5, 46-6, and 46-7 should be unsealed, but they disagreed about the remaining documents.
Legal standard
The court explained that parties may seal documents in a civil case only under a statute or rule, or with the court’s permission. Judicial records generally carry a common-law presumption of public access, although that right is not absolute. Depending on the documents’ role in the court’s decision-making, sealing requires either compelling reasons or an adequate countervailing reason against public access.
Analysis
The court said it did not yet know whether the documents would play a material role in resolving the summary-judgment motion because that motion remained unresolved. The court stated that it would reach the same result under either applicable access standard.
The court agreed that the four documents the parties identified for unsealing should be made public. As to the remaining documents, Dubanoski argued that they contained no personal information beyond names. Wells Fargo argued that they contained confidential personnel and disciplinary information about non-party employees, confidential business information, and confidential email communications. After reviewing the documents, the court found that each related to Wells Fargo’s internal complaint-investigation process and contained detailed information about sensitive personnel matters, including matters involving non-party employees. The court concluded that the legitimate confidentiality interests of Wells Fargo and the non-parties outweighed the public interest in unsealing the documents.
Order
The court granted the Joint Motion Regarding Continued Sealing. It directed the Clerk of Court to keep the documents filed at ECF Nos. 35, 46-4, 35-1, 38, 38-1, 41, 46-1, and 46-2 under seal. It directed the Clerk to unseal the documents filed at ECF Nos. 46-3, 46-5, 46-6, and 46-7. The court added that this ruling had no intended preclusive effect on how the District Judge might handle the documents or their contents when deciding dispositive motions or at trial.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.