Pauly v. Stanford Health Care
- Susan Illston
- 3:18-cv-05387
- U.S. District Court · Northern District of California
- 4
In Pauly v. Stanford Health Care, Judge Illston denied a motion to strike late filings and granted three motions to seal documents.
The ruling allowed Pauly’s late opposition, cross-motion for summary judgment, and supporting materials to remain filed, and it sealed the documents identified in the order. Stanford Health Care’s motion to strike was denied.
What happened
Pauly v. Stanford Health Care concerns a dispute about Stanford Health Care’s alleged failure to screen and treat Pauly when she was a minor. The defendant filed a motion for summary judgment, and Pauly filed an opposition and cross-motion one day late, followed shortly afterward by supporting documents.
Stanford Health Care asked the court to strike those filings as untimely. The court found that Pauly, who was representing herself, appeared genuinely confused about the deadlines, acted in good faith, and caused little delay or prejudice. The court also considered three motions to seal documents and noted that the defendant did not oppose them.
Judge Susan Illston denied the motion to strike and granted Pauly’s three administrative motions to file under seal. The order specifically identified Docket Nos. 168-4 and 169-4 as sealed documents.
The detailed version
- Pauly v. Stanford Health Care · No. 3:18-cv-05387
- Susan Illston
- Aug. 31, 2022
Background
The case concerns Stanford Health Care’s alleged failure to screen and treat Pauly when she was a minor in November and December 2008. The court had set July 22, 2022, as the deadline for dispositive motions, August 4 for oppositions, and August 12 for replies. The court later postponed the hearing on dispositive motions but stated that the briefing deadlines remained unchanged.
Stanford Health Care timely filed its motion for summary judgment on July 22. Pauly, who was representing herself, did not file her own summary-judgment motion by that deadline. She later filed an opposition to Stanford Health Care’s motion and a cross-motion for summary judgment shortly before midnight on August 5—one day after the opposition deadline. She filed supporting declarations and exhibits after midnight on August 6, attributing the delay to technical difficulties.
Motion to Strike
Stanford Health Care moved to strike Pauly’s opposition, cross-motion, and supporting declarations and exhibits because they were late. Pauly argued that she had understood the opposition deadline to be August 5 based on a local rule stating that oppositions must be filed no more than 14 days after a motion. The court rejected her argument that its scheduling order conflicted with that rule, explaining that the court could set deadlines in a pretrial order and that the order controlled the case unless modified.
The court nevertheless denied the motion to strike. Under Federal Rule of Civil Procedure 6, a court may extend a deadline after it has passed for “excusable neglect”—a legally recognized reason for allowing a late filing. The court considered the relevant factors, including prejudice, the length and effect of the delay, the reason for it, whether the delay was within the filer’s control, and good faith. It found that the delay was short, the resulting prejudice to Stanford Health Care was limited, and Pauly had acted in good faith. The court allowed the filings but reminded the parties that court-ordered deadlines must be followed.
Motions to Seal
Pauly filed three administrative motions to file documents under seal. Docket Nos. 168 and 169 sought to seal documents supporting her opposition and cross-motion for summary judgment. Docket No. 173 sought to seal documents filed by Stanford Health Care. Stanford Health Care did not oppose any of the motions. The court therefore granted Pauly’s motions to file under seal.
Disposition
The court denied Stanford Health Care’s motion to strike Pauly’s opposition, cross-motion for summary judgment, and supporting declarations. The court granted Pauly’s three administrative motions to file under seal. The order specifically identified Docket Nos. 168-4 and 169-4 as sealed. It did not list an additional document for Docket No. 173 in the conclusion.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.