Richard Dent v. National Football League
- William Alsup
- 3:14-cv-02324
- U.S. District Court · Northern District of California
- 2
In Richard Dent v. National Football League, Judge Alsup denied the NFL’s motion to seal documents supporting summary judgment because the request was overbroad and unsupported.
The National Football League and the plaintiffs, whose documents and health information were at issue in the sealing request.
What happened
Richard Dent and seven other plaintiffs sued the National Football League. The NFL sought to file many documents supporting its summary-judgment motion under seal because the plaintiffs had labeled them confidential and because they contained the plaintiffs’ personally identifiable health information.
The court said the public generally has a right to inspect judicial records. It also found that the confidentiality labels were overbroad and that the plaintiffs had not submitted the declarations required to support keeping the documents secret.
Judge Alsup denied the NFL’s motion to seal. The opinion did not decide the underlying summary-judgment motion.
The detailed version
- Richard Dent v. National Football League · No. 3:14-cv-02324
- William Alsup
- Dec. 17, 2021
Background
The National Football League filed an administrative motion asking the court to seal the entirety of many documents submitted in support of its motion for summary judgment. The NFL explained that the plaintiffs had designated the documents as confidential under the case’s protective order and that the documents contained the plaintiffs’ personally identifiable health information.
Legal standard
The court stated that the public generally has a right to inspect and copy judicial records. A party seeking to seal such records must overcome a strong presumption of public access by identifying compelling reasons, supported by specific factual findings, that outweigh the public’s interest in disclosure. The court also noted that sealing requests must be narrowly tailored and that a confidentiality designation or protective order alone does not establish that material may be sealed.
Ruling
The court found that the confidentiality designations were overbroad. It also found that the plaintiffs had filed no declarations supporting the request to keep the documents secret, as required by the court’s local rules. The court therefore denied the motion to seal. This order addressed sealing only; the opinion did not rule on the underlying motion for summary judgment.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.