Racies v. Quincy Bioscience, LLC

Background

Quincy Bioscience filed an administrative motion to seal Exhibit A to a declaration and portions of its brief concerning a dispute over whether it could cross-examine Phillip Racies about his medical condition.

Legal standard

The court explained that documents connected to a motion that does not decide the case are subject to the “good cause” standard under Federal Rule of Civil Procedure 26(c). That standard requires a specific showing of harm or prejudice from disclosure. A general confidentiality label or a protective-order designation is not enough.

Court’s reasoning

Quincy Bioscience’s only stated basis for sealing was that Racies had designated the information “Highly Confidential.” The court held that this designation did not establish that the documents could be sealed. The court also reviewed Exhibit A and determined that it did not appear to contain confidential information concerning Racies’s medical condition. The opinion additionally states that Racies did not file the declaration required by Civil Local Rule 79-5(e)(1), but the court denied Quincy Bioscience’s motion.

Ruling

The court DENIED Quincy Bioscience’s administrative motion to file under seal, including the request to seal Exhibit A and the unredacted version of the brief. It DIRECTED Quincy Bioscience to file public versions of all documents for which sealing was denied within seven days. The company could also file a new motion to seal within seven days that complied with the requirements discussed in the order. The order was issued by Judge Haywood S. Gilliam, Jr.