Anderson v. National Football League Management Council
- Donna Ryu
- 4:12-cv-06386
- U.S. District Court · Northern District of California
- 2
In Anderson v. National Football League Management Council, Judge Ryu denied without prejudice the defendant’s request to seal contempt-motion materials.
The National Football League Management Council, which was required to submit a compliant sealing request if it sought to keep the contempt-motion materials from public access; the materials remained subject to the court’s sealing procedures.
What happened
In Anderson v. National Football League Management Council, the National Football League Management Council asked to keep a contempt motion involving plaintiff Sammy Knight, its supporting evidence, and a proposed order entirely secret.
The defendant said sealing was necessary because the materials referred to previously sealed transcript documents. The court found that some references were to a publicly available order, and that only a small portion referred to nonpublic material.
Judge Donna Ryu denied without prejudice the request to seal because the defendant did not address the governing standards or follow the local sealing rules. The defendant could file an amended request by July 22, 2022.
The detailed version
- Anderson v. National Football League Management Council · No. 4:12-cv-06386
- Donna Ryu
- July 15, 2022
Background
On June 23, 2022, the National Football League Management Council filed a motion for contempt involving plaintiff Sammy Knight. It also filed an administrative motion asking to submit the entire contempt motion, the supporting evidence, and the proposed order under seal, meaning hidden from public access.
The defendant’s only stated basis for sealing was that the contempt materials referred to previously sealed transcript documents in three places. The court observed that portions of the motion cited the court’s April 23, 2014 publicly available order confirming an arbitration award. Of the material cited on another page, only lines 18 through 22 referred to nonpublic information.
Legal Standard
The court applied the strong presumption that court records should be publicly accessible. Under Ninth Circuit standards, a party seeking to seal judicial records must show compelling reasons and provide a factual basis for sealing rather than relying on speculation. If that standard is met, the court must balance the public’s interest in access against the interests of the party seeking secrecy.
The court also applied Northern District of California Local Rule 79-5. That rule requires a party to consider reasonable alternatives to sealing, limit the number of sealed documents, and avoid sealing entire documents when redaction would protect the sensitive information. Entire pleadings or briefs are strongly disfavored and may be sealed only in extraordinary circumstances.
Ruling
Judge Donna Ryu denied without prejudice the National Football League Management Council’s administrative motion to file the materials under seal. The court found that the defendant had not addressed the governing legal standards and had not complied with Local Rule 79-5. The denial without prejudice allowed the defendant to file another sealing motion, provided it addressed the legal standards and strictly complied with the local rule. The court set July 22, 2022, as the deadline for any amended motion to seal.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.