Sandoval Delgado v. Diaz Marquez
- Virginia Demarchi
- 5:23-cv-05141
- U.S. District Court · Northern District of California
- 3
In Sandoval Delgado v. Diaz Marquez, Judge Demarchi granted the parties’ motion to seal exhibits protecting a child’s identity and private health information.
The order affects Wilfrido Sandoval Delgado, Verania Diaz Marquez, their minor child JASD, and public access to the specified trial exhibits.
What happened
In Sandoval Delgado v. Diaz Marquez, Wilfrido Sandoval Delgado and Verania Diaz Marquez jointly asked the court to seal exhibits admitted during their bench trial. They said the materials included photos and videos of their minor child, identified as JASD, and a forensic medical evaluation of Ms. Diaz.
The court found compelling reasons to protect the child’s identity and Ms. Diaz’s private health information. It ordered several listed exhibits sealed. For Exhibit 38, which contained WhatsApp messages and photos of JASD, the court required redaction of the photos but not the text messages.
Judge Demarchi granted the motion. The order also covered an unredacted version of Exhibit 49 already filed publicly and directed the parties to prepare a redacted public version of Exhibit 38.
The detailed version
- Sandoval Delgado v. Diaz Marquez · No. 5:23-cv-05141
- Virginia Demarchi
- Feb. 16, 2024
Background
Wilfrido Sandoval Delgado and Verania Diaz Marquez jointly filed an administrative motion to seal exhibits admitted during a bench trial. They asked to seal photos and videos of their minor child, identified as JASD, and Exhibit 49, a forensic medical evaluation of Ms. Diaz.
Legal standard
Court records are generally presumed to be publicly accessible. Because the records involved a dispute resolved at trial, the court applied the stronger “compelling reasons” standard. Under that standard, the party seeking to seal records must show compelling reasons that outweigh public access and must explain why a less restrictive alternative would not be sufficient.
Court’s reasoning
The court found that protecting JASD’s identity was a compelling reason to seal the photos and videos. For most of the exhibits, the court found no less restrictive alternative than complete sealing.
Exhibit 38 consisted of WhatsApp messages between the parties and included some photos of JASD. The court concluded that complete sealing was unnecessary for that exhibit. Instead, only the photos had to be redacted from the public version; the text messages did not have to be redacted.
The court also found that protecting Ms. Diaz’s private health information was a compelling reason to seal Exhibit 49. Because an unredacted version had already been filed publicly at Docket No. 48-8, the court treated the motion as requesting that document’s sealing and the filing of Exhibit 49 entirely under seal.
Disposition
Judge Virginia K. Demarchi granted the motion to seal. The order required sealing of Exhibits 4, 6 through 10, 13 through 24, 49, 50A, 93, 322, and 325. It also ordered the parties to prepare a redacted version of Exhibit 38 consistent with the order for public posting.
Read the full 3-page opinion on CourtListener, the free public archive maintained by the Free Law Project.