M.G. v. Bodum USA, Inc.
- Joseph Spero
- 3:19-cv-01069
- U.S. District Court · Northern District of California
- 2
In M.G. v. Bodum USA, Inc., Judge Spero denied Bodum’s sealing motion without prejudice and required a renewed motion addressing the applicable standard.
Bodum USA, Inc.’s request to seal M. G.’s settlement-related filings was denied without prejudice, so Bodum may file a renewed sealing motion.
What happened
M. G. v. Bodum USA, Inc. concerns Bodum’s request to keep M. G.’s proposed settlement motion, supporting declaration, and exhibits from public view. M. G. did not oppose the request.
The court said recent Ninth Circuit decisions supported using the stricter “compelling reasons” standard for these documents, rather than the “good cause” standard Bodum relied on. The court therefore denied Bodum’s motion without prejudice, allowing Bodum to file it again.
Judge Joseph C. Spero directed Bodum’s renewed motion to address whether all of the documents meet the applicable standard and allowed Bodum to argue that the compelling-reasons standard should not apply.
The detailed version
- M.G. v. Bodum USA, Inc. · No. 3:19-cv-01069
- Joseph Spero
- May 5, 2021
Background
Bodum filed an administrative motion under Civil Local Rule 79-5 seeking permission to file under seal M. G.’s motion to approve a settlement, the supporting declaration, and attached exhibits. The motion was unopposed. Bodum argued that there was good cause to seal the documents.
Court’s Analysis
The court explained that recent Ninth Circuit authority indicates that the request was governed by the “compelling reasons” standard. That standard applies when filed materials are more than tangentially related to the merits of a case. The opinion cited decisions stating that motions related to settlements may be subject to this stricter standard.
Ruling
The court denied Bodum’s motion without prejudice to refiling. It directed Bodum, in a renewed motion, to address whether the documents it sought to seal satisfied the applicable standard in their entirety. The court also permitted Bodum to argue why the compelling-reasons standard should not apply.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.