Dignity Health v. Aramark Healthcare Support Services, LLC

Background

Dignity Health asked the court to file a “Master Service Agreement” under seal. The request was unopposed.

Legal standard

The court explained that the applicable standard depends on whether the filing is connected to a dispositive motion, which could resolve claims or the case, or a non-dispositive motion. For a dispositive motion, the party seeking to seal court records must show compelling reasons to overcome the strong presumption of public access. For a non-dispositive motion, the party generally must show good cause under Federal Rule of Civil Procedure 26(c).

Under either standard, a general reference to a category of privilege is not enough without explaining how it relates to the specific documents. The court also noted that the Northern District of California’s local rules require a sealing request to show that the material is privileged, a trade secret, or otherwise legally protected, and to seek sealing only for material that actually qualifies for protection.

Reasoning and ruling

The court found that Dignity Health offered only a generic reason for sealing and did not narrowly tailor its request to information that was truly sensitive. The court therefore denied sealing of the Master Service Agreement and directed Dignity Health to file an unredacted copy on the public docket by January 2, 2020.