City of San Mateo v. Argonaut Insurance Company
- Martinez-Olguin
- 3:23-cv-02504
- U.S. District Court · Northern District of California
- 5
In City of San Mateo v. Argonaut Insurance, Judge Martinez-Olguin granted in part and denied in part Argonaut’s motion to seal court filings.
City of San Mateo and Argonaut Insurance Company, concerning public access to their court filings and supporting documents; the order also addressed deposition transcripts involving plaintiffs in an underlying state-court case.
What happened
City of San Mateo v. Argonaut Insurance Company concerned Argonaut Insurance Company’s request to keep parts of its court filings and supporting documents secret.
The request covered portions of an opposition brief, paragraphs in a declaration, deposition transcripts, and a July 28, 2022 letter. The City supported sealing the letter and related brief passages, took no position on the transcripts, and gave no reason to keep the other identified materials sealed.
Judge Araceli Martinez-Olguin granted in part and denied in part the motion. She allowed the deposition transcripts, the letter, and brief passages describing the letter to remain sealed, but denied sealing for one generic brief sentence and paragraphs 4–7 of the declaration.
The detailed version
- City of San Mateo v. Argonaut Insurance Company · No. 3:23-cv-02504
- Martinez-Olguin
- Jan. 25, 2024
Background
Argonaut Insurance Company filed an administrative motion to seal portions of its opposition to the City of San Mateo’s motion for summary judgment, portions of the declaration of Joan Olfers, full transcripts of state-court plaintiffs’ deposition testimony, and a July 28, 2022 letter.
The court noted that Argonaut’s motion did not comply with the applicable local rule or the court’s standing order and warned that future noncompliant filings would be summarily struck. The City did not timely file a supporting declaration, but the court allowed it to file one by January 18, 2024. The City’s declaration took no position on sealing the deposition transcripts, asserted that the July 28, 2022 letter was protected by attorney-client privilege and attorney work-product protection, and asked that the letter and related portions of Argonaut’s opposition remain sealed. The declaration did not address the other requested materials.
Legal standard
Court records are subject to a strong presumption of public access. The party seeking to seal them must show compelling reasons supported by specific facts, explain the harm that would result from disclosure, and show that sealing is narrowly tailored and that a less restrictive alternative is insufficient.
Rulings
The court granted the motion to seal Exhibit 1 to the Olfers declaration, which contained the full deposition transcripts of the state-court plaintiffs. The court found the testimony sensitive, noted that the transcripts were not specifically cited or considered in deciding the underlying motion for partial summary judgment, and observed that the deponents had not been served with the sealing motion. The court denied sealing for the generic sentence on page 15, line 22, because it cited the transcripts without disclosing the underlying testimony.
The court granted the motion to seal Exhibit 2, the July 28, 2022 letter, because it was subject to attorney-client privilege. It also granted sealing for page 20, footnote 5, and page 20, line 21 through page 21, line 11, of Argonaut’s opposition because those portions described or quoted the privileged communication.
The court denied sealing for paragraphs 4–7 of the Olfers declaration. It found that those paragraphs described Exhibits 1 and 2 without revealing their substance, and the City had provided no reason for keeping them sealed.
Effect of the order
Documents for which the motion was granted would remain under seal. The City could file a supplemental declaration supporting sealing of materials for which the motion was denied by February 1, 2024. If it did not, Argonaut was required to file public versions of those documents by February 8, 2024.
Read the full 5-page opinion on CourtListener, the free public archive maintained by the Free Law Project.