Evans v. Presidio Trust
- Haywood Gilliam
- 4:19-cv-08025
- U.S. District Court · Northern District of California
- 4
In Evans v. Presidio Trust, Judge Gilliam provisionally granted Evans’s motion to seal materials claimed to contain trade secrets and health information.
Robert Evans’s requested confidentiality interests and the public’s interest in access to court records were affected. The ruling provisionally kept the specified materials sealed while leaving the trade-secret question unresolved.
What happened
In Evans v. Presidio Trust, Robert Evans asked to seal materials he said contained trade secrets and personal health information. The materials concerned strategies for helping the Presidio achieve financial self-sufficiency and were apparently intended for use in Evans’s opposition to a motion to dismiss.
The court applied the rule requiring compelling reasons to overcome the public’s presumptive right to access court records. It found that the claimed trade secrets could justify sealing if they were legally protected, and that the selected health information provided a separate reason for sealing. The court did not decide whether the materials actually contained protectable trade secrets.
The court provisionally granted Evans’s administrative motion to seal. Judge Haywood S. Gilliam, Jr. said the materials could later be unsealed in full if the court determined they were not trade secrets.
The detailed version
- Evans v. Presidio Trust · No. 4:19-cv-08025
- Haywood Gilliam
- Oct. 6, 2020
Background
Robert Evans moved to seal several documents that he contended were protectable as trade secrets. He identified pages describing his proprietary strategies for helping the Presidio reach financial self-sufficiency goals. He also sought to seal a paragraph containing information about his health history. The court presumed that the documents were intended for Evans’s opposition to the defendant’s motion to dismiss, which was due October 16, 2020.
Legal standard
Courts generally apply a “compelling reasons” standard to requests to seal judicial records. This standard recognizes a strong presumption that court records should be publicly accessible. The party seeking secrecy must provide specific reasons that outweigh the public interest in understanding the judicial process. The Northern District of California’s local rule also requires the request to be narrowly tailored and limited to material that is privileged, protectable as a trade secret, or otherwise protected by law.
Court’s analysis
The court explained that the federal Defense of Trade Secrets Act and the California Uniform Trade Secrets Act protect information that derives economic value from not being generally known, among other requirements. If Evans’s financial processes and strategies qualified as trade secrets rather than general industry knowledge, the court said, compelling reasons would exist to seal documents describing them. Because the validity of the claimed trade secrets was central to the case, the court provisionally granted the sealing request and stated that it would revisit the issue after the claimed trade secrets were evaluated on the merits.
The court separately found a compelling reason to seal the selected portions of the paragraph containing Evans’s health history because that material was personal and sensitive.
Disposition
The court provisionally granted Evans’s administrative motion to seal, Dkt. No. 36. It cautioned that this order was not a decision that the materials actually contained protectable trade secrets under either statute. If the court later reached the merits and concluded that the materials were not trade secrets, it said it would unseal the materials in their entirety.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.