Postpichal v. Cricket Wireless, LLC
- William Alsup
- 3:19-cv-07270
- U.S. District Court · Northern District of California
- 3
In Freitas v. Cricket Wireless, Judge Alsup granted plaintiffs’ motion to seal exhibits but required account-number redactions.
The order affected Ursula Freitas and Jamie Postpichal, the class members whose information appeared in the exhibits, Cricket Wireless, LLC, and the public’s access to the exhibits.
What happened
In Ursula Freitas and Jamie Postpichal v. Cricket Wireless, LLC, the plaintiffs asked to keep several exhibits filed after an earlier order under seal. The exhibits concerned a motion that the court found only tangentially related to the underlying claims.
The court applied the lower “good cause” standard for sealing because the motion did not affect the plaintiffs’ claims under the Racketeer Influenced and Corrupt Organizations Act. The exhibits contained class members’ sensitive personal information, including account numbers for services with Cricket Wireless.
Judge William Alsup granted the motion to seal to the extent stated in the order. He required all account numbers to be redacted but ruled that the class members’ names and resident states could not be redacted.
The detailed version
- Postpichal v. Cricket Wireless, LLC · No. 3:19-cv-07270
- William Alsup
- Mar. 31, 2022
Background
Plaintiffs Ursula Freitas and Jamie Postpichal sought to keep several exhibits under seal. They had filed the exhibits in response to an earlier order granting a motion for clarification.
Sealing standards
Judicial records generally carry a strong presumption of public access. For records closely related to the underlying claims, a party ordinarily must show “compelling reasons” to overcome that presumption. For records unrelated or only tangentially related to the claims, the party instead must show “good cause,” meaning specific prejudice or harm if the records are not protected. The court also noted that parties must consider reasonable alternatives to sealing, minimize the material sealed, and redact sensitive information rather than seal entire documents when possible.
Court’s analysis
The court found that the motion for clarification was only tangentially related to the underlying claims because it had no effect on plaintiffs’ claims under the Racketeer Influenced and Corrupt Organizations Act. The court therefore applied the good-cause standard.
The court found good cause to protect the exhibits because they contained sensitive personal information about class members, including account numbers for services with Cricket Wireless. The court concluded that this information could be used for improper purposes. But it also found that redaction was an adequate alternative to sealing the exhibits in full.
Disposition
The court granted plaintiffs’ motion to seal to the extent stated in the order. It ordered that all account numbers be redacted. It ruled that the names and resident states of the class members could not be redacted because the public and the class members had a right to know that information.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.