Wilkins v. Macomber
- Susan Illston
- 3:16-cv-00221
- U.S. District Court · Northern District of California
- 3
In Wilkins v. Macomber, Judge Illston granted Wilkins’s sealing motions, denied Macomber’s, and found two remaining motions moot.
Keenan G. Wilkins and Jeff Macomber, as well as public access to the court filings and exhibits addressed by the order.
What happened
In Wilkins v. Macomber, the parties asked the court to seal various exhibits and filings. Wilkins sought to seal medical records, medical reports, and a settlement transcript. Macomber sought to seal materials from hearings about Wilkins’s requests for a new appointed lawyer.
The court said records connected to the substance of a case can be sealed only when compelling reasons outweigh the public’s general right to access court records. It found compelling reasons to seal Wilkins’s exhibits because they contained confidential medical information and a settlement transcript whose terms limited what could be publicly discussed.
Judge Susan Illston granted Wilkins’s two sealing motions and denied Macomber’s motion because the hearing transcripts had previously been accessible during Wilkins’s direct appeal. The court found Macomber’s motions to strike and to file a revised filing partly under seal moot.
The detailed version
- Wilkins v. Macomber · No. 3:16-cv-00221
- Susan Illston
- Mar. 29, 2022
Background
The court considered several motions concerning whether exhibits and a filing should be placed under seal. Wilkins filed motions to seal exhibits at Docket Nos. 155 and 157. Macomber filed a motion to seal exhibits at Docket No. 142, along with a motion to strike the First Amended Memorandum in Support of Answer at Docket No. 143 and a motion to file that memorandum partly under seal at Docket No. 144.
Legal standard
The court explained that judicial records are generally presumed to be open to public inspection. Documents more than tangentially related to the merits of a case may be sealed only when the party seeking secrecy shows compelling reasons that outweigh the public’s interest in access and disclosure.
Court’s analysis
The court found compelling reasons to seal Wilkins’s Exhibits S through Z because they contained medical records or reports treated as confidential under California law. It also found a compelling reason to seal Exhibit AA, a transcript describing a settlement in litigation between Wilkins and various Alameda County actors. Although the settlement itself was not confidential, the agreement restricted Wilkins from publicizing anything beyond the fact of settlement.
The court denied Macomber’s motion to seal Exhibits Q, volume 1, T, U, W, HH, JJ, LL, MM, NN, and SS. Those exhibits concerned Wilkins’s requests for a new appointed lawyer and related hearings. The court noted that the materials had initially been filed on the public docket and that the procedural history showed prior public access to them during Wilkins’s direct appeal. Because of that history, the court was not satisfied that Wilkins’s privacy interests outweighed the public’s interest in access. The court also noted that California law permits the People to obtain transcripts of these hearings when a defendant challenges the denial of such a request on direct appeal.
Disposition
The court GRANTED Wilkins’s motions at Docket Nos. 155 and 157, DENIED Macomber’s motion at Docket No. 142, and found the motions at Docket Nos. 143 and 144 MOOT. The order was signed by United States District Judge Susan Illston on March 29, 2022.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.