DOE v. Apple Inc. Health and Welfare Benefit Plan
- Edward Davila
- 5:22-cv-02566
- U.S. District Court · Northern District of California
- 7
In Jane Doe v. Apple Inc. Health and Welfare Benefit Plan, Judge Davila granted in part and denied in part sealing motions, while denying Doe’s sealing request without prejudice.
Jane Doe and Apple Inc. Health and Welfare Benefit Plan, whose requested filings and supporting materials were subject to the sealing rulings; the order also addressed public access to those court records.
What happened
In Jane Doe v. Apple Inc. Health and Welfare Benefit Plan, both sides asked to keep parts of their filings related to Defendant’s motion to dismiss under seal.
The court found compelling reasons to seal the confidential settlement agreement, material directly quoting or describing that agreement and settlement negotiations, and specified portions of Defendant’s filings. It rejected broader redactions that were not narrowly tailored or sought to conceal information already publicly disclosed.
Judge Edward J. Davila granted in part and denied in part Defendant’s motions to seal, and denied Jane Doe’s motion to seal without prejudice because it did not identify the requested material as required by local rules. Defendant could file revised redactions, and Jane Doe could renew her request, by February 28, 2023.
The detailed version
- DOE v. Apple Inc. Health and Welfare Benefit Plan · No. 5:22-cv-02566
- Edward Davila
- Feb. 15, 2023
Background
The order addressed three administrative motions to seal filed in connection with Defendant Apple Inc. Health and Welfare Benefit Plan’s motion to dismiss Jane Doe’s complaint. Both parties sought to seal portions of their briefs and supporting materials.
Legal standard
Because the requested materials were more than tangentially related to the underlying cause of action, the parties had to show compelling reasons supported by specific facts to overcome the strong presumption of public access to court records. The court also applied the requirement that sealing requests be narrowly tailored to seal only material eligible for protection.
Defendant’s motions
The court found compelling reasons to seal the parties’ Confidential Settlement Agreement and Release dated December 21, 2021. It relied on the policy favoring protection of confidential settlement materials, as well as the sensitive personal and medical history involved, Jane Doe’s status as a minor at the time of the events, and her decision to sue under the name Jane Doe.
The court also granted sealing for portions of Defendant’s filings that quoted the settlement agreement or referred so directly to the agreement or settlement negotiations that disclosure would effectively reveal the agreement. But the court found that some proposed redactions were too broad, lacked a sufficiently particularized justification, or covered information Defendant had already disclosed publicly. The court therefore granted in part and denied in part Defendant’s motions to seal.
Jane Doe’s motion
The court denied Jane Doe’s motion to seal without prejudice. The motion attached unredacted documents but did not highlight the portions for which sealing was sought, and the proposed order did not list the requested sealed portions in the table format required by the local rules.
Order
Judge Edward J. Davila ordered Defendant to submit a revised redacted version of its opening brief by February 28, 2023. Jane Doe could renew her sealing request by filing submissions that complied with Civil Local Rule 79-5 by the same date. If revised submissions were not filed, the court stated that it would unseal the documents in their entirety, except for direct quotations from the settlement agreement.
Read the full 7-page opinion on CourtListener, the free public archive maintained by the Free Law Project.