TechShop, Inc. v. Rasure
- Haywood Gilliam
- 4:18-cv-01044
- U.S. District Court · Northern District of California
- 3
In TechShop v. Rasure, Judge Gilliam denied defendants’ motions to seal because confidentiality labels alone did not satisfy sealing rules.
The ruling affected defendants’ requests to keep specified motion and exhibit materials from public view. It also required defendants to file public versions of the affected documents, while allowing them to submit new sealing motions that complied with the court’s requirements.
What happened
In TechShop, Inc. v. Rasure, defendants asked to seal parts of their motions in limine and supporting exhibits. They relied only on TechShop’s designations of the materials as “confidential” or “highly confidential.”
The court ruled that those designations alone did not show that sealing was justified under the required good-cause standard. The court denied all three motions, ordered defendants to file public versions of the affected documents within seven days, and allowed them to file new sealing motions that complied with the rules.
Judge Haywood S. Gilliam, Jr. issued the order. The ruling concerned public access to court filings and did not decide the parties’ underlying claims.
The detailed version
- TechShop, Inc. v. Rasure · No. 4:18-cv-01044
- Haywood Gilliam
- Mar. 10, 2020
Background
Defendants filed three administrative motions asking to file materials under seal in connection with motions in limine and responses to TechShop’s motions in limine. The requested materials included portions of two motions in limine and several exhibits.
Legal standard
Because motions in limine are nondispositive motions, meaning they do not ordinarily decide the claims in the case, the court applied the lower “good cause” standard under Federal Rule of Civil Procedure 26(c). That standard requires a particularized showing that disclosure would cause specific prejudice or harm. General claims of harm are not enough. The court also noted that a confidentiality designation by a party does not itself establish that a document may be sealed.
Court’s reasoning
The only justification offered for sealing was that TechShop had designated the information as “confidential” or “highly confidential.” The court held that this designation was insufficient under Civil Local Rule 79-5(d)(1)(A), because it was merely a designation made under the parties’ protective order and did not establish good cause for sealing.
The court also found that TechShop, as the party that designated the materials, did not comply with Civil Local Rule 79-5(e)(1), which required it to file a declaration within four days of defendants’ motions.
Disposition
The court denied defendants’ administrative motions to file materials under seal, identified as Docket Nos. 127, 129, and 173. It directed defendants to file public versions of all documents for which sealing had been denied within seven days. The court also stated that defendants could file new motions to seal within seven days if those motions complied with the requirements discussed in the order.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.