Hyams v. CVS Health Corporation
- Haywood Gilliam
- 4:18-cv-06278
- U.S. District Court · Northern District of California
- 4
In Hyams v. CVS Health, Judge Gilliam denied plaintiffs’ motion to seal exhibits and ordered public filings within seven days.
The ruling directly affected the plaintiffs’ ability to keep exhibits supporting their class-certification motion from public view. It also affected the defendants as the parties that had designated some materials confidential, and it preserved public access to the documents for which sealing was denied.
What happened
In Hyams v. CVS Health Corporation, the plaintiffs asked the court to keep numerous exhibits supporting their motion for class certification from public view.
The plaintiffs relied largely on “Confidential” designations and separately argued that Ryan Hyams’s pay records contained sensitive salary information. The defendants did not file the declaration required for materials they had designated confidential.
Judge Haywood S. Gilliam, Jr. denied the motion to seal. He ordered the plaintiffs to file public versions of the documents within seven days, while allowing them to file a new motion that follows the court’s requirements.
The detailed version
- Hyams v. CVS Health Corporation · No. 4:18-cv-06278
- Haywood Gilliam
- Mar. 18, 2021
Background
The plaintiffs filed an administrative motion asking to seal numerous exhibits attached to Beth Gunn’s declaration supporting their motion for class certification. They sought to seal the exhibits based primarily on confidentiality designations. They also sought to seal Exhibit 79, which contained Ryan Hyams’s pay records, because they characterized the records as sensitive information.
Legal standard
The court explained that judicial records generally are subject to a strong presumption of public access. Because the motion for class certification was more than tangentially related to the underlying case, the court applied the “compelling reasons” standard. Under that standard, the party seeking to seal records must identify specific reasons that outweigh the public interest in disclosure. Civil Local Rule 79-5 also requires a sealing request to be narrowly tailored to material that is legally protectable, such as privileged information or trade secrets.
Analysis
The court held that simply labeling documents “Confidential” under a stipulated protective order did not establish that the documents could be sealed. The plaintiffs’ motion therefore did not comply with Civil Local Rule 79-5(d)(1)(A). The defendants, which had designated the materials, also failed to file the declaration required by Civil Local Rule 79-5(e)(1). The court accordingly denied the request to seal the exhibits based on the confidentiality designation.
As to Exhibit 79, the court noted that at least some information in the pay records—such as labels describing the type of earnings—was not salary information. Because the plaintiffs sought to seal the entire exhibit rather than narrowly identifying material that was properly sealable, the court denied the motion to seal Exhibit 79 in its entirety.
Ruling and effect
Judge Haywood S. Gilliam, Jr. denied the plaintiffs’ administrative motion to file the documents under seal. The court directed the plaintiffs to file public versions of all documents for which sealing was denied within seven days of the order. The court also stated that the plaintiffs could file a new motion to seal within seven days if it complied with the requirements discussed in the order.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.