Paredes v. City of San Jose

Background

Anthony Luis Paredes filed an administrative motion to seal videos that he submitted with his opposition to the defendants’ motion to dismiss. The defendants submitted a statement supporting the motion to seal.

Legal standard

Judicial records generally carry a strong presumption of public access. Because the videos were submitted in connection with a motion addressing the merits of Paredes’s claims, the court applied the “compelling reasons” standard. Under that standard, the party seeking sealing must show interests that outweigh public access, explain the harm that would result from disclosure, and show that a less restrictive alternative would not be sufficient.

Court’s reasoning

The court found compelling reasons to seal the videos. First, they showed third parties who had been arrested by police but were not involved in the case, raising privacy concerns. Second, the court had not considered the videos when deciding whether to grant the defendants’ motion to dismiss because the videos were not part of the relevant pleading. The court therefore concluded that disclosure would not, at that stage, help the public understand the judicial process.

Disposition

The court granted Paredes’s motion to seal the videos without prejudice to unsealing them later if the court considers them.