Day v. GEICO Casualty Company
- Beth Freeman
- 5:21-cv-02103
- U.S. District Court · Northern District of California
- 3
In Day v. GEICO Casualty Company, Judge Freeman granted GEICO’s motion to seal confidential financial and business information filed with its class-certification opposition.
GEICO, which may keep the specified financial and proprietary information under seal, and members of the public seeking access to those court filings.
What happened
Day v. GEICO Casualty Company concerned GEICO’s request to seal portions of its opposition to Jessica Day’s motion for class certification and two supporting declarations. The materials contained nonpublic financial information about GEICO’s operations in California.
The court said documents related to class certification could be sealed only for compelling reasons. GEICO argued that public disclosure could give competitors an advantage, and Day did not oppose the request.
Judge Beth Labson Freeman ruled that GEICO had shown compelling reasons to seal the information because disclosure threatened its competitive interests. The court granted the sealing motion for the specified portions of GEICO’s response and the two entire declarations.
The detailed version
- Day v. GEICO Casualty Company · No. 5:21-cv-02103
- Beth Freeman
- Aug. 24, 2022
Background
GEICO filed a corrected administrative motion asking the court to seal portions of its opposition to Jessica Day’s motion for class certification, along with two supporting declarations. GEICO identified the material as nonpublic, confidential financial information about its operations in California. GEICO’s counsel stated that competitors could use the information to GEICO’s disadvantage if it became public. Day did not oppose the motion.
Legal standard
Courts generally recognize a public right to inspect judicial records. Because the requested materials related to class certification, the court applied the “compelling reasons” standard. That standard requires a strong justification for keeping court filings from public view. The court also applied the Northern District of California’s Civil Local Rule 79-5, which requires the moving party to identify the reasons for sealing, explain the injury that would result from disclosure, address whether a less restrictive alternative would suffice, and provide supporting evidence when necessary.
Court’s analysis
The court found that GEICO met the compelling-reasons standard. It concluded that releasing information about GEICO’s internal financial results and sensitive proprietary business issues threatened GEICO’s competitive interests.
Ruling
The court granted GEICO’s sealing motion as follows:
- ECF No. 93: The highlighted portions of GEICO’s response to Day’s motion for class certification were ordered sealed, including the portions identified at pages 1:7–8, 2:14–15, 3:9–19, 4:1–12, 4:25, 5:1–11, 5:13, 5:14, 5:17–27, 8:24–25, 12:12–13, 16:6–7, and 16:11. - ECF No. 93-1: The entire declaration of Russell Ward in support of GEICO’s response was ordered sealed. - ECF No. 93-2: The entire declaration of William in support of GEICO’s response was ordered sealed.
The order addressed only GEICO’s request to seal these materials; it did not decide the motion for class certification or the underlying claims.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.