Laughlin v. Stuart
- Eric Tostrud
- 0:19-cv-02547
- U.S. District Court · District of Minnesota
- 8
Laughlin v. Stuart: Magistrate Judge Leung denied two requests to unseal documents and ordered six documents to remain sealed.
Michael B. Hari and Kenneth Lewis, whose requests were denied and whose identified documents remain sealed; the County Defendants, whose showing of good cause supported continued sealing.
What happened
In Laughlin v. Stuart, plaintiffs Michael B. Hari and Kenneth Lewis asked the court to reconsider an earlier sealing decision and to unseal documents they said contained no private or confidential information.
The court concluded that the documents were connected to non-dispositive discovery motions, were not judicial records, and therefore had no presumption of public access. It also found that the defendants had shown good cause for keeping them sealed because they contained identifying information about jail personnel and security procedures.
Magistrate Judge Leung denied both requests and ordered documents numbered 133, 134, 137, 144, 147, and 159 to remain sealed.
The detailed version
- Laughlin v. Stuart · No. 0:19-cv-02547
- Eric Tostrud
- Apr. 9, 2021
Background
The court had previously entered a protective order governing confidential information in the case. Several documents filed by Michael B. Hari and Kenneth Lewis were placed under temporary seal because they contained or cited information that Anoka County defendants had designated confidential. The documents included reply briefs, exhibits supporting discovery-related motions, and Hari’s objection to an earlier order.
The court had previously granted in part and denied in part a joint motion concerning continued sealing and then permanently sealed the documents. Hari and Lewis later filed a letter seeking permission to ask for reconsideration, and Hari filed a formal motion requesting further consideration under Local Rule 5.6(d)(3).
Analysis
The court denied the letter-based motion because it did not formally comply with Local Rule 5.6. The court also noted that Hari filed a proper motion seven days later and that the letter was largely duplicative of that motion.
The court denied Hari’s formal motion as well. It explained that the documents were reply memoranda and exhibits connected to non-dispositive discovery motions, along with an objection to rulings on those motions. Because the court did not consider the reply filings when deciding the underlying motions, the court determined that the documents were not “judicial records” and therefore did not carry a presumption of public access.
For documents that are not judicial records, the court applied a “good cause” standard, meaning the party seeking continued sealing must show that sealing is needed to prevent harm such as annoyance, embarrassment, oppression, or undue burden. The court found that the County Defendants had shown good cause because the documents contained identifying information about jail personnel and security procedures. The court also stated that the documents contained information related to ongoing criminal matters in its earlier sealing order.
Disposition
The court ordered the following:
- Hari and Lewis’s Continued Sealing/Request for permission to file a motion to reconsider was DENIED.
- Hari’s Motion for Further Consideration of Sealing of Documents 133, 134, 137, 144, 147, and 159 was DENIED.
- Documents numbered 133, 134, 137, 144, 147, and 159 were ordered to remain sealed.
- Prior consistent orders remained in effect.
The order was signed by Tony N. Leung, United States Magistrate Judge.
Read the full 8-page opinion on CourtListener, the free public archive maintained by the Free Law Project.