Gonzalez v. City of Alameda
- Donna Ryu
- 4:21-cv-09733
- U.S. District Court · Northern District of California
- 2
In Gonzalez v. City of Alameda, Judge Ryu granted Arenales’ motion to seal an irrelevant footnote in a discovery letter.
Edith Arenales, the Gonzalez Plaintiffs, and the public’s access to the footnote in the joint discovery letter.
What happened
In Gonzalez v. City of Alameda, Edith Arenales asked the court to seal a footnote in a joint discovery letter. The footnote referred to an email from Julia Sherwin, counsel for the Gonzalez Plaintiffs.
The court applied a lower standard for sealing records connected to non-dispositive motions, requiring a showing of good cause. It found good cause because the email was irrelevant to the discovery dispute, the court’s earlier ruling, and the case.
The court granted Arenales’ motion to seal. Judge Donna M. Ryu issued the order on December 4, 2023.
The detailed version
- Gonzalez v. City of Alameda · No. 4:21-cv-09733
- Donna Ryu
- Dec. 4, 2023
Background
Edith Arenales moved to have the court consider whether another party’s material should be sealed. The Gonzalez Plaintiffs, who had designated the material, supported the motion. They sought to seal a footnote in the parties’ July 27, 2023 joint discovery letter. The footnote referred to an email that Julia Sherwin, counsel for the Gonzalez Plaintiffs, sent to a legal listserv. Arenales objected to Sherwin’s declaration and to the request to seal.
Legal standard
Court records generally carry a strong presumption of public access. For records connected to dispositive motions, courts ordinarily require compelling reasons to seal them. But the court explained that a lower “good cause” standard applies to records connected to non-dispositive motions, such as the joint discovery letter at issue here. Good cause is the standard under Rule 26(c) of the Federal Rules of Civil Procedure for this type of material.
Court’s reasoning
The court found good cause to seal the footnote because Sherwin’s email was entirely irrelevant to the parties’ discovery dispute, the court’s August 11, 2023 ruling on that dispute, and the action. The court therefore determined that sealing the footnote was appropriate.
Disposition
The court granted Arenales’ motion to seal. The order was signed by Chief Magistrate Judge Donna M. Ryu.
Read the full 2-page opinion on CourtListener, the free public archive maintained by the Free Law Project.