True Health Chiropractic Inc v. McKesson Corporation

Background

Defendants filed an administrative motion to seal several exhibits submitted in support of their motion to decertify the class and their concurrently filed motion for partial summary judgment. The exhibits included nonpublic spreadsheets containing personally identifiable information for defendants’ customers.

Legal standard

For court records filed with motions that are closely related to the merits of a case, the court generally applies a “compelling reasons” standard. Under that standard, the party seeking secrecy must identify specific reasons that outweigh the public’s general right to inspect court records. Civil Local Rule 79-5 also requires the request to be narrowly tailored and supported by a showing that the material is privileged, a trade secret, or otherwise legally protected.

Court’s reasoning

The court determined that defendants’ filings connected to the class-decertification motion were more than tangentially related to the underlying claims, so the compelling-reasons standard applied. The court found that defendants met their burden because the spreadsheets contained nonpublic, competitively sensitive customer information. It also found that this information generally constituted trade secrets, that the public interest in releasing the particular spreadsheets was limited, and that defendants had a strong interest in keeping potentially trade-secret information confidential. Balancing those interests, the court concluded that the information should remain sealed.

Ruling

Judge Haywood S. Gilliam, Jr. granted defendants’ administrative sealing motion. Under Civil Local Rule 79-5(f)(1), the documents covered by the granted motion will remain under seal. The opinion states that the court deferred ruling on defendants’ motion for partial summary judgment.