Hyams v. CVS Health Corporation
- Haywood Gilliam
- 4:18-cv-06278
- U.S. District Court · Northern District of California
- 3
In Hyams v. CVS Health Corporation, Judge Gilliam denied Plaintiffs’ request to seal exhibits and ordered public versions filed within seven days.
The ruling directly affected Plaintiffs’ request to keep exhibits and related materials secret and required public versions to be filed; it also addressed Defendants’ obligations as the parties that designated the materials confidential.
What happened
In Hyams v. CVS Health Corporation, the plaintiffs asked to keep several exhibits supporting their motion for partial summary judgment secret. The request covered entire exhibits and deposition and discovery materials.
The court said the plaintiffs had to show compelling reasons for sealing because the materials were connected to a potentially case-dispositive motion. The plaintiffs relied only on the materials’ confidentiality designation, which was not enough. The defendants also did not file the declaration required by the court’s local rules.
Judge Haywood S. Gilliam, Jr. denied the plaintiffs’ administrative motion to seal and directed them to file public versions of all documents for which sealing was denied within seven days of the order.
The detailed version
- Hyams v. CVS Health Corporation · No. 4:18-cv-06278
- Haywood Gilliam
- Mar. 18, 2021
Background
Plaintiffs filed an administrative motion asking the court to file under seal various exhibits to the declaration of Beth Gunn, which supported Plaintiffs’ motion for partial summary judgment. The request sought to seal all of Exhibits 12 through 15, including deposition exhibits and documents produced in discovery.
Legal standard
The court explained that judicial records generally carry a strong presumption of public access. For records connected to a dispositive motion—a motion that could resolve the case or a claim—the party seeking secrecy must provide specific facts showing compelling reasons that outweigh the public’s interest in disclosure. The request must also be narrowly tailored to cover only material entitled to legal protection under Civil Local Rule 79-5.
The court noted that a lower “good cause” standard applies to records attached to nondispositive motions. That standard was not used here because Plaintiffs’ partial-summary-judgment motion was more than tangentially related to the underlying action.
Discussion
The only justification offered for sealing was that the materials had been designated confidential. The court held that a confidentiality designation is merely a party’s initial designation under a stipulated protective order and does not, by itself, establish that documents can be sealed. The court therefore found that Plaintiffs’ motion did not comply with Civil Local Rule 79-5(d)(1)(A).
The court also found that Defendants, as the parties that designated the materials, did not comply with Civil Local Rule 79-5(e)(1) because they did not file the required declaration within four days of Plaintiffs’ motion.
Ruling
The court denied Plaintiffs’ administrative motion to file the documents under seal. It directed Plaintiffs to file public versions of all documents for which sealing had been denied within seven days of the order. The opinion does not state the later filing status of those documents.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.