Patel v. Alphabet Inc.
- Beth Freeman
- 5:23-cv-03647
- U.S. District Court · Northern District of California
- 3
In Patel v. Alphabet, Judge Freeman granted in part and denied in part Patel’s third reconsideration motion, allowing limited medical redactions.
Raj Patel, whose Fourth Amended Complaint may contain limited redactions for private medical and health information; the previously publicly filed complaints and the motion concerning his application to proceed without paying court fees remain public.
What happened
In Patel v. Alphabet Inc., Raj Patel asked the court to reconsider its earlier refusal to seal his Fourth Amended Complaint and other filings.
The court allowed redaction of five groups of paragraphs containing private medical or health information, but denied reconsideration for all other paragraphs. Earlier publicly filed complaints and Patel’s motion about his application to proceed without paying court fees will remain public.
Judge Beth Labson Freeman granted in part and denied in part the motion and ordered Patel to file a properly redacted complaint or an amended complaint by September 15, 2023. The order warned that failing to do so may cause the complaint to be stricken and the case dismissed with prejudice.
The detailed version
- Patel v. Alphabet Inc. · No. 5:23-cv-03647
- Beth Freeman
- Sept. 8, 2023
Background
Raj Patel filed a third motion asking the court to reconsider its earlier order denying his request to file under seal his Fourth Amended Complaint, earlier versions of his complaint, and his motion concerning the denial of his application to proceed without paying court fees. The court had allowed this third motion to proceed only for the limited purpose of deciding whether private medical information should be sealed.
Legal standard
Because a complaint is closely related to the merits of a case, the court applied the “compelling reasons” standard. Under that standard, a party seeking to seal judicial records must explain why sealing is necessary, identify the harm that would result from public access, explain why a less restrictive alternative would not work, provide supporting evidence when necessary, and request sealing narrowly.
Ruling
The court found that most of Patel’s proposed redactions did not involve private medical information or any confidential information. The examples included legal citations, public webpages, Google searches, and arguments about making certain public figures’ caste information available. The court found that those requests did not meet the compelling-reasons standard.
The court granted reconsideration as to paragraphs 584, 615–616, 626, and 628 of the Fourth Amended Complaint because they contained private medical and health information. It denied reconsideration as to all other paragraphs of that complaint. Because Patel did not request redactions for the previously publicly filed versions of his complaint or for his motion concerning the application to proceed without paying court fees, those documents will remain on the public docket.
Order
Judge Beth Labson Freeman ordered Patel to file the Fourth Amended Complaint on the public docket with the permitted redactions, or to amend it to remove material he does not want to file publicly, by September 15, 2023. The order states that failure to file a properly redacted or amended complaint may cause the operative complaint to be stricken and the case dismissed with prejudice. It also states that no further reconsideration motions will be permitted on this sealing issue.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.