Guzman v. Chipotle Mexican Grill, Inc.

Background

The plaintiffs filed an administrative motion seeking permission to keep Exhibit 13 under seal. The exhibit was submitted in support of the plaintiffs’ opposition to the defendants’ motion for summary judgment. The opinion identifies Exhibit 13 as a services agreement.

The defendants represented that the exhibit contained proprietary and nonpublic information about their operations, business strategies, and finances. They argued that disclosure could harm them because competitors could use the information to their disadvantage.

Legal standard

For records connected to a dispositive motion, such as a motion for summary judgment, the court generally applies a “compelling reasons” standard. The party seeking to seal the record must identify specific reasons that outweigh the public’s strong interest in access to court records. Civil Local Rule 79-5 also requires the request to be narrowly tailored to material that is privileged, a trade secret, or otherwise legally protectable.

Court’s analysis

The court noted that the parties had reached a settlement. Because of the settlement, the court did not rely on Exhibit 13, and the summary-judgment motion was denied as moot in a separate ruling. The court concluded that the exhibit was unrelated to the public’s understanding of the proceedings because the court would not decide the merits of the summary-judgment motion.

The court found that the exhibit disclosed confidential business information concerning the defendants’ operations and that disclosure would provide little public benefit in this case. It therefore found both a compelling reason and good cause to keep the exhibit under seal.

Disposition

The court GRANTED the administrative motion to file Exhibit 13 under seal. Under Civil Local Rule 79-5(f)(1), Docket No. 102-2 was to remain under seal.