UnifySCC v. Cody

Background

The County of Santa Clara filed an administrative motion asking to file under seal certain exhibits supporting its opposition to the plaintiffs’ motion to certify a class. The requested redactions covered personally identifying information belonging to County employees, including names, employee identification numbers, phone numbers, email addresses, and home addresses. The plaintiffs did not oppose the motion.

Legal standard

The court explained that court filings and attachments that are more than tangentially related to the merits may be sealed only for “compelling reasons.” It also noted that Civil Local Rule 79-5 requires a party seeking sealing to explain the interests supporting sealing, provide evidentiary support when necessary, and narrowly tailor the request to seal only material that may properly be sealed.

Court’s analysis

The court applied the compelling-reasons standard because the documents concerned class certification. It found compelling reasons to seal the employees’ personal information. The court stated that names, addresses, phone numbers, and email addresses are appropriately protected, and that employee identification numbers can be used to obtain other sensitive information, such as income and leave status. The court also found that the information was not material to the motion to certify a class.

The court further found that the request was narrowly tailored because the County sought to seal only the personally identifying information and no other information in the exhibits.

Ruling

The court granted the County’s administrative motion to file under seal, ECF No. 93. It granted the request for the highlighted portions of the listed declarations and exhibits, including exhibits to declarations by Bryan Anderson, Megan Doyle, Jeffrey Draper, Mathew Fisk, Christopher Grumbos, and Sonia Menzies. This order addressed sealing only; the opinion did not decide the plaintiffs’ motion to certify a class.