Dew v. City of Seaside
- Haywood Gilliam
- 4:19-cv-06009
- U.S. District Court · Northern District of California
- 3
In Dew v. City of Seaside, Judge Gilliam granted plaintiffs’ motion to seal documents containing minors’ full names.
The order affects Lori Dew, the minor plaintiffs G.V., W.V., B.V., and L.V., the appointed guardians ad litem Maryann Gould and Marilyn Corpus, and public access to the identified court documents.
What happened
In Lori Dew, et al. v. City of Seaside, et al., the plaintiffs asked the court to appoint guardians for four minor plaintiffs and to seal documents supporting that request. The court had already appointed the guardians on March 10, 2020.
The court applied a lower “good cause” standard because the motion to appoint guardians was not a motion that would decide the case. The court found good cause because the documents contained the minors’ full names and related only to the guardian appointments, not the case’s underlying claims.
Judge Haywood S. Gilliam, Jr. granted the plaintiffs’ motion to seal the documents. The order was entered on April 15, 2020.
The detailed version
- Dew v. City of Seaside · No. 4:19-cv-06009
- Haywood Gilliam
- Apr. 15, 2020
Background
Plaintiffs Lori Dew and minors G.V., W.V., B.V., and L.V. filed an administrative motion asking the court to appoint guardians ad litem for the minors and to seal documents attached to that request. A guardian ad litem is a person appointed to represent a minor’s interests in a case. The documents included the guardianship petitions, verifications and consent forms from Maryann Gould and Marilyn Corpus, and a declaration from Jeremy I. Lessem.
The court had already granted the request to appoint guardians on March 10, 2020. It appointed Maryann Gould as guardian ad litem for G.V. and Marilyn Corpus as guardian ad litem for W.V., B.V., and L.V. The remaining issue addressed in this order was whether to seal the supporting documents.
Legal standard
The court explained that documents attached to motions that do not decide the case are generally subject to a “good cause” standard rather than the stricter “compelling reasons” standard. Good cause requires a particularized showing that disclosure would cause specific harm or prejudice. The request must also be narrowly tailored to seal only material entitled to protection.
Analysis and ruling
The court found good cause to seal the documents because they contained the full names of minors, which receive privacy protection under Federal Rule of Civil Procedure 5.2(a)(3). The court also found that the documents were relevant only to the guardian-ad-litem appointment motions and were not relevant to the merits of the case.
The court granted plaintiffs’ motion to seal the documents. The order does not state that the underlying case was resolved.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.