Cameron Dyess v. Estate of Jajuan Lee Morton

Background

Plaintiff Cameron Dyess filed administrative motions asking to file documents under seal in connection with PA Solutions’ first and second motions for summary judgment. The sealing requests covered Exhibit 4 to declarations by Jonathan M. Shuggart and portions of Dyess’s oppositions and declarations that referred to the exhibit.

PA Solutions submitted declarations supporting the sealing requests. It said the exhibit included an email about its internal employee-expense reimbursement practices, emails with a potential client, and a contract concerning its arrangement for procuring rental vehicles. PA Solutions argued that disclosure could harm its competitive position by revealing internal practices, negotiation tactics, expense information, and pricing information.

Legal standard

Because the documents were connected to summary-judgment motions, the court applied the “compelling reasons” standard. That standard starts with a strong presumption that court records should be available to the public. The party seeking sealing must identify specific reasons that outweigh the public’s interest in access. Civil Local Rule 79-5 also requires a sealing request to be narrowly tailored to material that is privileged, a trade secret, or otherwise legally protected.

The court noted that records connected to nondispositive motions are evaluated under the lower “good cause” standard, but it did not apply that standard here. The court also explained that a document’s designation as “Confidential” under a protective order does not by itself establish that the document may be sealed.

Court’s analysis

The court recognized that some information, including specific rates PA Solutions charged clients for its personnel, might justify sealing. But it found that the proposed redactions were not narrowly tailored. The requests did not explain why sealing the entirety of Exhibit 4 was necessary or why portions of the oppositions and declarations that discussed the documents generally should be sealed.

The court also found that some redacted material was not proprietary and was discussed elsewhere in the record. It specifically identified general information about insurance coverage as material for which there was no basis to seal.

Disposition

The court DENIED Plaintiff’s administrative motions to file under seal. It DIRECTED Plaintiff to file public versions of all documents for which sealing had been denied within seven days of the order. The parties could also file a new motion to seal within seven days, provided that the request identified, for each item, the relevant public and provisionally sealed docket numbers, the document name, the specific portions sought to be sealed, and specific supporting reasons and authorities.