Lansdale v. UPS Supply Chain Solutions, Inc.
- John Tunheim
- 0:16-cv-04106
- U.S. District Court · District of Minnesota
- 4
In Lansdale v. UPS, Judge Tunheim kept the summary-judgment order sealed but required a redacted public version limited to still-sealed information.
Michael L. Lansdale, UPS Supply Chain Solutions, Inc., and members of the public seeking access to the court’s summary-judgment order.
What happened
In Lansdale v. UPS Supply Chain Solutions, Inc., the court considered whether to unseal its earlier order on the parties’ summary-judgment motions. The court decided that the order should remain sealed because it referred to some information that was still sealed.
Lansdale argued that the entire order should remain sealed, or that substantial portions should be redacted, because many records had been labeled confidential and because the order might be misunderstood by the public or prospective employers. The court rejected those arguments, explaining that most of the referenced information was already public and that the public has a strong right to access judicial opinions.
Judge John R. Tunheim ordered that the summary-judgment order remain sealed and that a redacted version be filed. The redactions must be limited to information that remains both sealed and redacted in the record.
The detailed version
- Lansdale v. UPS Supply Chain Solutions, Inc. · No. 0:16-cv-04106
- John Tunheim
- Oct. 10, 2018
Background
The court had previously directed the parties to explain why its memorandum opinion and order on their motions for summary judgment should not be unsealed and to identify any portions that should be redacted. The court noted that the summary-judgment order referred to some information that remained sealed.
Lansdale argued that the order should remain sealed, or that lengthy portions should be redacted, for two reasons: many exhibits and portions of deposition testimony had been designated confidential and filed under seal, and the order allegedly omitted important facts that could cause the public, including prospective employers, to view Lansdale negatively.
Court’s Analysis
The court explained that Federal Rule of Civil Procedure 26(c) permits protection from specified harms for good cause, but that courts also recognize a common-law presumption favoring public access to judicial records. The presumption is especially strong for judicial opinions because the public has a right to understand the court’s decision and reasoning.
The court found that nearly all documents referenced in the summary-judgment order had since been unsealed or made public in redacted form. It therefore would not seal or redact portions referring to information already publicly available. It would redact references to information that remained sealed and redacted in the record.
The court also rejected Lansdale’s concern about possible reputational harm. It stated that the order made clear that many material factual disputes remained and that the order did not present an exhaustive account of Lansdale’s termination. The court concluded that the asserted risk of public misunderstanding did not overcome the public’s right of access.
Disposition
The court ordered that the memorandum opinion and order on motions for summary judgment, Docket No. 237, remain sealed. It also ordered that a redacted version be filed, with redactions limited to information that remained both sealed and redacted in the record.
Read the full 4-page opinion on CourtListener, the free public archive maintained by the Free Law Project.