Steward v. County of Santa Clara
- Susan Illston
- 3:18-cv-04119
- U.S. District Court · Northern District of California
- 3
In Steward v. County of Santa Clara, Judge Illston denied defendants’ motion to seal without prejudice because it was overbroad and unsupported.
The defendants’ request to keep the declaration and exhibits from public access was denied, but they could renew the request in a narrower form. The ruling also concerned public access to records filed with the court.
What happened
In Steward v. County of Santa Clara, defendants asked to seal Sergeant Jose Morales’s entire declaration and Exhibits 1 through 23, which supported their motion for summary judgment.
The court said records connected to a dispositive motion are presumed accessible unless the requesting party shows compelling reasons for secrecy and seeks only narrowly tailored redactions. Defendants’ general references to confidential body-camera footage, surveillance video, searches, contraband watch, and rehousing reports did not explain why all of the materials needed sealing.
Judge Susan Illston denied defendants’ administrative motion without prejudice to renewal. Defendants could submit a narrower motion explaining specifically what information was confidential, and the court set February 5, 2020, as the deadline for doing so; it also required a chambers copy of any renewed motion.
The detailed version
- Steward v. County of Santa Clara · No. 3:18-cv-04119
- Susan Illston
- Jan. 28, 2020
Background
Defendants filed an administrative motion to seal the entire declaration of Sergeant Jose Morales and Exhibits 1 through 23. The materials supported defendants’ motion for summary judgment. Defendants stated that the materials contained confidential information concerning the County of Santa Clara Sheriff’s Office’s body-worn-camera footage, surveillance video, strip and contraband searches, contraband watch, and rehousing reports.
Legal standard
For documents filed in connection with a dispositive motion, the court applies a strong presumption of public access. The party seeking to seal records must identify compelling reasons, supported by specific facts, that outweigh the public’s interest in understanding the judicial process. A sealing request must also be narrowly tailored, meaning it should seek to withhold or redact only information that truly requires confidentiality.
Court’s analysis
The court found that defendants’ motion, as presented, did not establish a compelling reason for sealing and was not narrowly tailored. The supporting declaration did not identify particular confidential information in Sergeant Morales’s declaration or address the individual exhibits. Defendants also did not explain why the entire declaration needed to be sealed, and most or all of its contents did not appear confidential. In addition, the publicly filed complaint already alleged facts about the November 7, 2016 strip search, including digital penetration, so at least some of the material was already part of the public record.
The court likewise found that defendants had not explained why all 23 exhibits should be sealed. It noted that redaction might be difficult for video footage and said that sealing the entire strip-search footage might be appropriate, but defendants still had to identify the confidential material and limit the request.
Disposition
Judge Susan Illston denied defendants’ administrative motion to seal without prejudice to renewal. The court permitted defendants to file a renewed, more narrowly tailored motion by February 5, 2020, in compliance with the applicable local rule and the court’s standing order. Any renewed motion had to explain specifically why the material was confidential and use redactions where appropriate. The court also stated that defendants had not provided a chambers copy of the original motion and supporting declaration and required a chambers copy if they filed a second motion.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.