Benner v. Saint Paul Public Schools, I.S.D. 625

Background

The parties filed a joint motion under Local Rule 5.6 asking the court to continue sealing documents that had been temporarily sealed in connection with the defendants’ motion for summary judgment. The parties agreed that ECF No. 93 should be unsealed. The court therefore directed the clerk to unseal that filing.

The parties disagreed about eight other filings: four sets of school human-resources investigation and discipline documents concerning Benner; a declaration by the mother of a school student; excerpts from and the complete deposition of that student’s mother; and partially redacted attendance records for some district teachers.

Legal standard

The court explained that the public has a common-law right of access to judicial records. Local Rule 5.6 recognizes a qualified presumption that the public may access filed materials. The right is not absolute, however, and the court must weigh the public interest in transparency against legitimate confidentiality interests.

The public interest is stronger when documents are used in connection with the court’s exercise of its federal judicial power, such as a request for summary judgment, than when documents concern a non-dispositive matter such as discovery. The court therefore treated the public interest in access to these filings as substantial.

Rulings on the sealed documents

For ECF Nos. 80, 81, 82, and 83, the defendants argued that federal and Minnesota privacy laws protected confidential student information. They maintained that the information could identify students even after names and initials were redacted. Benner argued that the redactions were sufficient to prevent disclosure of confidential student data. After reviewing the documents, the court found the defendants’ confidentiality interest strong, noted the heightened importance of protecting minors’ privacy, and ordered these four filings to remain under seal.

For ECF Nos. 84, 85, and 90, the defendants again argued that the filings disclosed private student information. Benner again argued that the redactions adequately addressed the privacy concerns. The court concluded that the confidentiality interest outweighed the public’s interest in access and ordered these three filings to remain under seal.

For ECF No. 92, the defendants argued that the less-redacted teacher attendance records contained private personnel information, including sick days and some illnesses involving teachers’ children. The court found that the public interest in transparency was adequately served because the same records were partially available in ECF No. 93, which the court ordered unsealed. The court therefore ordered ECF No. 92 to remain under seal.

Disposition

The clerk was directed to unseal ECF No. 93 and keep ECF Nos. 80, 81, 82, 83, 84, 85, 90, and 92 under seal. This order addressed access to filed materials; it did not decide the defendants’ motion for summary judgment or the underlying claims.