California Spine and Neurosurgery Institute v. United Healthcare Insurance…

Background

California Spine and Neurosurgery Institute sued United Healthcare Insurance Company and Does 1 through 25 for breach of an implied-in-fact contract and breach of an express contract. United Healthcare asserted a counterclaim against California Spine for money had and received. United Healthcare moved to file under seal Exhibit 4 to a supplemental declaration supporting its motion for summary judgment. Both parties submitted declarations supporting the sealing request.

Legal standard

The court explained that judicial records generally carry a strong presumption of public access. Because Exhibit 4 supported a summary-judgment motion, which is closely related to the merits of the case, United Healthcare had to show compelling reasons for sealing the requested information. The request also had to be narrowly tailored under the court’s local sealing rule.

Reasons for sealing

The court considered two categories of information. First, Exhibit 4 contained data about the amounts California Spine had been paid for certain medical procedures. California Spine stated that the information was not publicly or commercially available and that disclosure could cause specific harm in future negotiations with health plans and insurance companies. The court found that the competitive harm from disclosure was a compelling reason that outweighed the general policy favoring public access.

Second, Exhibit 4 contained patients’ personal health information. The court found that protecting this information was also a compelling reason that outweighed public access. The court therefore approved redaction of both the payment amounts and the patients’ health information.

Disposition

Judge Lucy Koh granted United Healthcare’s motion to file Exhibit 4 under seal. This order decided only the sealing request; it did not decide the summary-judgment motion, the contract claims, or the counterclaim.