Monfort v. Adomani
- Lucy Koh
- 5:18-cv-05211
- U.S. District Court · Northern District of California
- 6
In Monfort v. Adomani, Judge Koh partly granted and partly denied Monfort’s request to keep exhibits sealed in this summary-judgment case.
Plaintiff Edward R. Monfort and Defendants were affected by the sealing rulings and the order to confer and file a renewed motion; the public’s access to the court records was also at issue.
What happened
Monfort v. Adomani concerned Plaintiff Edward R. Monfort’s request to keep exhibits supporting his opposition to Defendants’ summary-judgment motion from public view. He sought to seal two of his own exhibits and documents that Defendants had labeled confidential.
The court granted the request for Exhibits D and F to Monfort’s declaration because they contained attorney-client communications. It denied with prejudice the request for Exhibits D, I, Y, 6, 14, and 15 to Kristen O’Connor’s declaration because Defendants said those exhibits did not need to remain sealed. It denied without prejudice the request covering the remaining exhibits designated confidential by Defendants because the request was too broad and did not identify the specific material that could properly be sealed.
Judge Lucy Koh ordered the parties to confer and jointly file a narrower renewed sealing motion by December 6, 2019, following the district’s filing requirements. The order addressed public access to court records and did not decide the underlying summary-judgment motion.
The detailed version
- Monfort v. Adomani · No. 5:18-cv-05211
- Lucy Koh
- Nov. 22, 2019
Background
Defendants had filed a motion for summary judgment, and Monfort filed an opposition with supporting exhibits. Monfort then filed an administrative motion asking to keep certain exhibits under seal. The request covered Exhibits D and F to Monfort’s declaration and twenty exhibits to the declaration of Kristen O’Connor that Defendants had designated confidential.
Legal standard
The court explained that court records generally carry a strong presumption of public access. Because the records related to a motion for summary judgment, a dispositive motion, the parties had to show compelling reasons supported by specific facts that outweighed the public’s interest in access. They also had to follow Civil Local Rule 79-5, which requires a sealing request to identify material that is privileged, a trade secret, or otherwise legally protected, and to seek sealing only as narrowly as necessary.
Rulings
The court granted Monfort’s motion as to Exhibits D and F to his declaration because they contained attorney-client communications, which the court recognized as a sufficient basis for sealing under the applicable standard.
For exhibits designated confidential by Defendants, the court stated that Defendants acknowledged Exhibits D, I, Y, 6, 14, and 15 did not need to be sealed. The court therefore denied with prejudice Monfort’s administrative motion to seal those exhibits.
The court denied without prejudice Monfort’s motion concerning the remaining exhibits designated confidential by Defendants: Exhibits E, F, H, L, M, N, O, P, R, S, T, X, Z, and 3 to O’Connor’s declaration. The court found the request overbroad because it sought to seal large portions of documents without identifying which specific passages contained sealable information. As an example, the court noted that an email chain in Exhibit N mostly concerned discussions about Monfort and contained only passing references to internal company financial information.
The order’s summary table labels the O’Connor-declaration exhibits as “DENIED” without repeating the “with prejudice” or “without prejudice” qualifiers stated in the preceding discussion. The prose portion of the order is therefore the source of the specific qualifiers summarized above.
Further order
The court ordered Defendants to confer with Monfort to identify the specific portions of the remaining exhibits that contain sealable information. The parties were ordered to jointly file a renewed, narrowly tailored administrative motion by December 6, 2019. The renewed filing was to comply with Civil Local Rule 79-5 and be submitted in one electronic docket entry with the specified supporting materials. This order ruled on the sealing request, not on Defendants’ motion for summary judgment.
Read the full 6-page opinion on CourtListener, the free public archive maintained by the Free Law Project.