Andrade v. Costco Wholesale Corporation
- Thomas Hixson
- 3:23-cv-06125
- U.S. District Court · Northern District of California
- 3
In Andrade v. Costco, Judge Hixson granted Andrade’s motion to seal medical records and photographs attached to her opposition to summary judgment.
The ruling protects Isabella Andrade’s medical privacy while limiting public access to the specified portions of Exhibit B; it did not decide Costco’s motion for summary judgment.
What happened
Isabella Andrade sued Costco Wholesale Corporation over claims arising from her employment. She asked the court to seal Exhibit B to a declaration filed with her opposition to Costco’s motion for summary judgment. Costco did not oppose the sealing request.
Exhibit B contained a medical record and four photographs showing Andrade’s medical treatment, disability, and a severe skin reaction. Andrade argued that public disclosure would cause particularized harm to her medical privacy.
Judge Thomas S. Hixson held that protecting Andrade’s medical privacy provided compelling reasons to seal the requested material and granted the administrative motion. The court noted that a redacted version was already publicly filed, so no further action was needed.
The detailed version
- Andrade v. Costco Wholesale Corporation · No. 3:23-cv-06125
- Thomas Hixson
- Dec. 15, 2025
Background
Isabella Andrade filed employment-related claims against Costco Wholesale Corporation. While Costco’s motion for summary judgment was pending, Andrade filed an administrative motion under Civil Local Rule 79-5 seeking to seal Exhibit B to the Declaration of Stephen Noel Ilg. Exhibit B was attached to Andrade’s opposition to Costco’s summary-judgment motion.
The requested material consisted of a medical record covering pages ANDRADE000045–57 and four medical photographs: one taken in an emergency room and three documenting a severe skin reaction. Andrade argued that public disclosure would cause concrete, particularized harm to her medical privacy. Costco did not oppose the motion.
Legal standard
Because the material was filed in connection with a summary-judgment motion, the court applied the “compelling reasons” standard. That standard starts with a strong presumption that judicial records should be publicly accessible. A party seeking to seal such records must show compelling reasons, supported by specific facts, that outweigh the public’s interest in disclosure.
Court’s analysis
The court reviewed the portions Andrade asked to seal and found that the request was narrowly tailored to private medical records and photographs of her disability. The court determined that protecting medical privacy qualified as a compelling reason to seal the requested material.
Disposition
The court granted Andrade’s administrative motion to seal Exhibit B, ECF No. 33-3. Because a redacted version had already been filed publicly as ECF No. 31-2, the court stated that no further action was needed. The order did not decide Costco’s motion for summary judgment.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.