Paredes v. City of San Jose

Background

Anthony Luis Paredes moved to seal an exhibit to his Third Amended Complaint. The exhibit included deposition information about a police officer who had been disciplined for violating the department’s canine policy in an incident in which a police dog bit a suspect’s leg. Paredes and the defendants relied on a protective order, and the defendants supported sealing the exhibit.

Legal standard

The court explained that court records carry a strong presumption of public access. A party seeking to seal materials closely connected to the claims—such as materials filed with a complaint—must show compelling reasons supported by specific facts that outweigh the public’s interest in disclosure. The less demanding “good cause” standard applies to some discovery materials that are only tangentially related to the underlying claims, but the court held that the compelling-reasons standard applied here because the exhibit was filed with the complaint.

Reasons for the ruling

The defendants offered two arguments. First, they argued that the events described in the exhibit were irrelevant because they occurred after the events underlying Paredes’s claims. Second, they argued that the information was confidential under California Penal Code section 832.7, which generally protects peace-officer personnel records and information obtained from those records.

After the court ordered supplemental briefing, the defendants acknowledged that section 832.7 did not protect the information at issue. The statute contains exceptions for records involving a sustained finding of unreasonable or excessive force and incidents in which a peace officer’s use of force caused death or great bodily injury. The department had determined that this incident involved use of force causing great bodily injury, and the finding had been sustained.

The court recognized the privacy protections available to public employees, including law-enforcement officers. But it concluded that those protections did not extend to information about police use of force resulting in death or serious injury under the circumstances described. The court also stated that the information appeared relevant to Paredes’s claims, although relevance was not the decisive question. The defendants did not show that disclosure would serve an improper purpose or identify another compelling reason that outweighed public access.

Disposition

The court denied the motion to seal. It ordered Mr. Paredes to file an unredacted copy of Exhibit A to his Third Amended Complaint on the public docket within 14 days after the order was entered. The order addressed access to the exhibit and did not decide the underlying claims in the case.