Vaden v. Linn Star Transfer, Inc.

Background

Plaintiffs Faye Vaden and Alma Jackson filed an omnibus administrative motion asking the court to appoint Vaden as guardian ad litem for Jackson and to seal Jackson’s health and financial records attached to that motion. On December 4, 2019, the court granted the motion in part by appointing Vaden as Jackson’s guardian ad litem. This order addressed the request to seal.

Legal standard

The court explained that documents attached to a motion that could resolve a claim generally require “compelling reasons” for sealing. Documents attached to a motion that does not resolve a claim, however, are subject to the lower “good cause” standard. That standard requires a specific showing that disclosure would cause particular harm or prejudice. The court determined that the guardian-ad-litem motion was nondispositive, meaning it did not resolve the underlying lawsuit, so the good-cause standard applied.

Analysis and ruling

The court found good cause to seal Docket Nos. 54-3, Exhibits 1 and 2; 54-5; and 54-6. It found that the documents contained highly sensitive and confidential medical and banking records, or references to those records, and that the records were not the subject of the lawsuit. The records had instead been attached to explain Jackson’s need for a guardian ad litem.

The court also found that redacting the records would not adequately protect the sensitive information because the documents would still reveal information the public had no need to review in this case. It therefore granted the motion to seal those documents in their entirety. The court ordered Plaintiffs’ counsel to file a fully redacted version of the petition, without the sealed exhibits, by December 13, 2019. Judge Haywood S. Gilliam, Jr. signed the order.