DOE v. Apple Inc. Health and Welfare Benefit Plan
- Edward Davila
- 5:22-cv-02566
- U.S. District Court · Northern District of California
- 5
In Jane Doe v. Apple Inc. Health and Welfare Benefit Plan, Judge Davila granted in part and denied in part Doe’s motion to seal.
Jane Doe, Apple Inc. Health and Welfare Benefit Plan, and the public’s access to the court filings.
What happened
In Jane Doe v. Apple Inc. Health and Welfare Benefit Plan, Jane Doe asked to seal portions of her opposition to the Plan’s motion to dismiss and a supporting declaration. The materials referred to a confidential settlement agreement and settlement negotiations.
The court agreed that some references could remain sealed because they could effectively reveal the settlement agreement. But it found that Doe’s proposed redactions were not narrow enough and included information already disclosed publicly.
Judge Davila granted in part and denied in part the motion. The court ordered Doe to file revised redacted documents by March 28, 2023; otherwise, the documents would be unsealed in their entirety except for direct quotations from the settlement agreement.
The detailed version
- DOE v. Apple Inc. Health and Welfare Benefit Plan · No. 5:22-cv-02566
- Edward Davila
- Mar. 14, 2023
Background
Jane Doe filed an amended administrative motion asking to seal excerpts of her opposition to the defendant’s motion to dismiss and a supporting declaration. The requested redactions concerned the parties’ Confidential Settlement Agreement and Release dated December 21, 2021, as well as settlement negotiations. In an earlier order, the court had denied Doe’s prior sealing request without prejudice and allowed her to refile it under the court’s local rules.
Legal standard
Because the requested materials were connected more than tangentially to the underlying case, Doe had to show compelling reasons, supported by specific facts, for keeping them secret. The court also required the request to be narrowly tailored to seal only material that could properly remain confidential. The court noted that it had previously found compelling reasons to protect the settlement agreement, settlement communications, Doe’s identity, and information concerning her sensitive personal and medical history and her status as a minor when the events occurred.
Court’s analysis
The court maintained its prior finding that it was appropriate to seal portions of Doe’s opposition and declaration that quoted the settlement agreement or referred to the agreement or settlement communications so directly that the references would effectively disclose the agreement.
However, the court found that Doe’s proposed redactions were not narrowly tailored and that she had not provided enough specific justification for sealing all of the requested material. For example, some information—including the phrase “in the Utah Case”—had already appeared in publicly filed documents and therefore was not appropriate for sealing.
Ruling
Judge Edward J. Davila granted in part and denied in part Doe’s motion. For both the opposition brief and the declaration of Brian S. King, the court denied sealing as to the specific words and passages listed in its ruling and otherwise granted the requested sealing. The court directed Doe to file revised redacted versions by March 28, 2023. If she did not resubmit revised redactions by that date, the court stated that it would unseal the documents in their entirety, except for direct quotations from the settlement agreement.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.