Patel v. Alphabet Inc.
- Beth Freeman
- 5:23-cv-03647
- U.S. District Court · Northern District of California
- 2
In Patel v. Alphabet Inc., Judge Freeman denied without prejudice Patel’s request to seal case filings, allowing a narrower supported request.
Raj Patel’s court filings were at issue, and the ruling preserved public access to those filings unless Patel submits a narrower, adequately supported sealing request.
What happened
In Patel v. Alphabet Inc., Raj Patel asked to seal his Third Amended Complaint, three earlier complaints, and a motion to reconsider in their entirety. The request followed an earlier order dismissing his Second Amended Complaint with permission to amend.
The court said complaints are closely connected to the merits of a case, so sealing them requires “compelling reasons.” Patel did not show compelling reasons to seal all or any part of the filings.
Judge Beth Labson Freeman denied without prejudice the motion to file under seal. Patel may submit a narrower request to seal specific portions, supported by an affidavit, by September 6, 2023; otherwise, the documents will be filed publicly.
The detailed version
- Patel v. Alphabet Inc. · No. 5:23-cv-03647
- Beth Freeman
- Aug. 28, 2023
Background
The court had previously dismissed Raj Patel’s Second Amended Complaint with leave to amend and directed him to file a Third Amended Complaint within 30 days. Patel then moved to seal his Third Amended Complaint, his original complaint, his First Amended Complaint, his motion to reconsider, and his Second Amended Complaint.
Sealing standard
Federal courts generally recognize public access to judicial records. Under the standard applied by the court, filings more than tangentially related to the merits of a case may be sealed only for “compelling reasons.” A complaint meets that standard because it is closely related to the merits. The Northern District of California also requires a sealing request to explain the private or public interests supporting secrecy, the injury that would result from disclosure, and why a less restrictive alternative would not suffice. The request must include evidentiary support when necessary, and any proposed sealing must be narrowly tailored.
Ruling
The court found that Patel had not shown compelling reasons to seal all or any part of the pleadings. It therefore DENIED WITHOUT PREJUDICE Patel’s motion to file under seal, ECF No. 21. The court allowed Patel to file a narrower request to seal portions of the complaints, supported by an affidavit showing compelling reasons. The renewed request was due by September 6, 2023. The court stated that if Patel did not renew the request, the entire document would be filed on the public docket.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.