Tamrat v. Marlowe
- Phyllis Hamilton
- 4:20-cv-07623
- U.S. District Court · Northern District of California
- 2
In Tamrat v. Marlowe, Judge Hamilton granted defendants’ request to seal facility videos submitted with their summary-judgment motion.
The defendants, Herman Tamrat, inmates and staff at the Sonoma County Main Adult Detention Facility, and members of the public who might otherwise access the videos were affected. Tamrat was to receive the videos, but the videos were kept from the public court file.
What happened
Tamrat v. Marlowe involves a civil-rights lawsuit by a state prisoner who claims two sheriff’s deputies used excessive force at the Sonoma County Main Adult Detention Facility. The defendants submitted six videos of the facility with their motion asking the court to decide the case without a trial.
The defendants asked to keep the videos from public view because they showed housing areas, hallways, and the booking area that could be studied for tactical purposes, potentially threatening staff and inmate safety. They said the plaintiff would still receive the videos, while the publicly available motion described their contents without creating the same safety risk.
Judge Phyllis J. Hamilton granted the motion to file the videos under seal. The court found that the request was legally justified and narrowly limited, and directed the clerk to file the videos under seal.
The detailed version
- Tamrat v. Marlowe · No. 4:20-cv-07623
- Phyllis Hamilton
- Aug. 2, 2021
Background
Herman Tamrat, a state prisoner proceeding without a lawyer, brought a civil-rights complaint under 42 U.S.C. § 1983. The case concerned allegations that two defendant sheriff’s deputies used excessive force against him at the Sonoma County Main Adult Detention Facility. The defendants filed a motion for summary judgment, which asks the court to resolve the case without a trial, and submitted six videos from inside the facility.
The videos showed an inmate housing module, hallways, and the booking area. The defendants argued that members of the public could study the videos for tactical use, including people who might later be involved with current inmates, creating risks to the health and safety of staff and inmates. They asked the court to file the videos under seal, meaning that the public could not access them through the court’s public filings.
Sealing standard
The court explained that the party seeking to seal material bears the burden of showing that sealing is justified. Civil Local Rule 79-5 requires a court order before documents may be filed under seal and requires sealing requests to be narrowly tailored to material entitled to legal protection.
Ruling
The court found that the defendants met their burden. It noted that Tamrat would receive the videos, and that the defendants showed the videos were entitled to protection under the law to protect the health and safety of inmates and staff. The court also found the request narrowly tailored because the remainder of the summary-judgment motion would remain public and described the videos’ substance without jeopardizing safety.
Judge Phyllis J. Hamilton granted the defendants’ motion to file under seal, Docket No. 28, and requested that the clerk file the videos under seal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.