Pratt v. Kernan
- Lucy Koh
- 5:17-cv-04375
- U.S. District Court · Northern District of California
- 4
In Pratt v. Gamboa, Judge Koh granted both parties’ motions to seal medical records and related material.
Lawrence S. Gamboa and Michael Joseph Pratt; the order keeps specified medical records and related discussions from public access.
What happened
In Pratt v. Gamboa, both sides asked the court to keep medical records and related materials from public view. The materials included medical-record exhibits, deposition testimony discussing those records, and parts of Michael Joseph Pratt’s opposition to a summary-judgment motion.
The court said records connected to a summary-judgment motion may be sealed only for compelling reasons that outweigh the public’s usual right to access court records. It found that protecting medical privacy provided compelling reasons and that the requests were limited to medical information and discussions of it.
Judge Koh granted both administrative motions to file the materials under seal. This order did not decide the summary-judgment motion itself.
The detailed version
- Pratt v. Kernan · No. 5:17-cv-04375
- Lucy Koh
- May 22, 2020
Background
Defendant Lawrence S. Gamboa and Plaintiff Michael Joseph Pratt filed administrative motions to file materials under seal. The materials were submitted in connection with Gamboa’s motion for summary judgment.
Gamboa sought to seal three exhibits containing portions of Pratt’s medical records. Pratt sought to seal 24 exhibits containing medical-record excerpts or deposition testimony discussing those records. Pratt also sought to redact portions of his opposition to summary judgment that cited those exhibits.
Court’s analysis
The court explained that judicial records generally carry a strong presumption of public access. Because the requested materials related to summary judgment, the parties had to show “compelling reasons” supported by specific factual findings that outweighed that presumption. The court also required compliance with Civil Local Rule 79-5, including a narrowly tailored request covering only material entitled to legal protection.
The court found that protecting Pratt’s medical privacy was a compelling reason to seal the medical records. It also found the requests narrowly tailored because they covered only the medical records, deposition testimony discussing those records, and portions of Pratt’s opposition that similarly discussed them.
Disposition
The court granted the parties’ administrative motions to file under seal. The order addressed sealing only; it did not rule on the underlying summary-judgment motion.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.