L.S. v. Henderson

Background

The plaintiffs filed their second administrative motion asking to file documents under seal. The documents were associated with a non-dispositive motion, meaning a motion that does not resolve the case or a claim. The motion concerned multiple exhibits, including Exhibits D and E and materials supported by a declaration from Sergeant Zhou.

Reasoning

For documents attached to non-dispositive motions, the court required the plaintiffs to show “good cause,” meaning a sufficient specific justification for keeping the documents from public view.

The court found no good cause for sealing Exhibits D and E because both declarations appeared to be publicly available on the docket in a separate case. The court also found that the plaintiffs had not adequately explained why the remaining exhibits should be sealed. Sergeant Zhou’s statements that the matter was an open murder investigation and that disclosure could affect a future prosecution were conclusory and did not provide enough information to satisfy the good-cause standard.

Ruling

The court denied the plaintiffs’ motion entirely, without prejudice to a renewed request. The renewed request had to be narrower, more targeted, and supported by a stronger justification for withholding the information from public disclosure. It had to be filed within seven days, and the parties did not need to resubmit unredacted materials. If no renewed motion was filed within seven days, all the materials would be unsealed. Judge Vince Chhabria signed the order.